United States
Environmental Protection
Agency
Solid Waste and
Emergency Response
(5502G)
EPA520-F-92-006
Fall 1992
& EPA Super-fund At Work
Hazardous Waste Cleanup Efforts Nationwide
Site Description:
A waste disposal area in Bullitt County,
Kentucky
Site Size: 13 acres
Primary Contaminants:
Polychlorinated biprtenyls (PCBs),
heavy metals, polynucJear aromatics
(PAHs), and volatile organic com-
pounds (VOCs)
Potential Range of Health Risks
Without EPA Cleanup:
Skin irritation, increased risk of cancer
Nearby Population Affected:
100 within t mite
Ecological Concerns:
Contamination of Wilson Creek and
other tributaries of the Ohio River
Year Listed on NPL: 1983
EPA Region: IV
State: Kentucky
Congressional District: 2
Success In Brief
Valley of the Drums Cleanup:
A Superfund Benchmark
The Superfund program was designed to mitigate the dangers
posed by improper disposal of hazardous waste. The A.L. Taylor site,
also known as "Valley of the Drums," was one of the first challenges to
Superfund. Valley of the Drums was the scene of one of the largest
drum removals in the history of the program. The successful cleanup
was accomplished through some notable achievements, including:
A significant reduction of risks to local citizens and the
environment due to several emergency removal actions;
Use of state-of-the-art cleanup technologies;
* Combined efforts between the U.S. Environmental Protection
Agency (EPA) and the Kentucky Department of Natural Re-
sources and Environmental Protection (KDNREP); and
Recovery of $1.8 million of EPA's cleanup costs from polluters.
This cooperative effort among EPA, State and local groups crdrninated
in a cleanup of tremendous proportions and a safe community and
environment.
The Site Today
The completion of all
cleanup activities at Valley of
the Drums is a benchmark in
Superfund program achieve-
ments. The site has been
proposed for deletion from
EPA's list of the most serious
hazardous waste sites. Close
monitoring will continue for
the next 30 years to ensure the
effectiveness of the cleanup.
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, IL 60604-3590
Valley of the Drums Surface Water Treatment System
Improperly dumped
drums removed in
early actions
Limestone
filtration
removes
particulate
contaminant
Carbon filtration
absorbs
additional
contaminants
Surface
water
detained in
lagoon to
await
treatment
Decontaminated
water enters
Wilson Creek
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Superfund At Work Valley of the Drums, Bullitt County, KY
Fall 1992
The Valley of the Drums site
was an uncontrolled industrial
waste dump covering 13 acres
in a small valley in Bullitt
County, Kentucky. The site is
located in a rural area and
approximately 100 people live
within one mile. Over 17,000
drums of hazardous waste
were discovered on the surface
of the site. Investigations
A Site Snapshot
conducted in 1975 by the
Kentucky Department of
Natural Resources and Envi-
ronmental Protection
(KDNREP) revealed that
deteriorating and leaking
drums had discharged pollut-
ants into Wilson Creek, a
tributary of the Ohio River.
The pollutants identified at
this site included: heavy
metals, polynuclear aromatic
hydrocarbons (PAHs), volatile
organic compounds (VOCs),
and polychlorinated biphenyls
(PCBs). Contamination on-site
consists of approximately 140
different chemical compounds.
Because this site is in a rural
area, threats to local citizens
were not as pressing as the risk
of ecological damage to Wilson
Creek, and the potential for
contamination to spread to the
Ohio River. Evidence of this
critical environmental problem
was demonstrated by the lack of
vegetation on and near various
areas of the site property.
Although the site was
privately owned and fenced,
trespassers faced potential health
threats from contact with con-
taminants present in site soil and
surface water. The potential
human health effects related to
these contaminants range from
skin irritation to an increased
risk of cancer.
Valley of the Drums
Site Timeline
Polluter files bankruptcy, ceases cleanup efforts 4
EPA samples area wells, installs new and maintains ^
existing carbon filtration units
KDNREP requests EPA assistance \
1 EPA performs emergency cleanup actions
KDNREP orders owner to cease operations
KDNREP partially removes pollutants from Wilson Creek
KDNREP identifies contamination at the site,
takes legal action against owner
Improper disposal of hazardous wastes at the site
1967
1975 1976 1977
1979 1980
Page 2
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Superfund At Work
Valley of the Drums, Bullitt County, KY
Fall 1992
Valley of the Drums:
Ten Years of Unlicensed Dumping
Produces A Sea of Corroded, Leaking Drums
Valley of the Drums
Bullitt County, KY
Site Conditions Require State
to Take Immediate Actions
During the 10 years that the
Valley of the Drums site was
used to dispose of industrial
chemicals and
municipal
refuse, the
owner of the
property
never applied
for the re-
quired State
permits. In that time, many
drums were improperly buried
on-site and some drums were
drained into open pits and re-
cycled. Open pits were also used
for burning solvents and, in the
later years of operation, many
drums were haphazardly dis-
carded on the site surface.
In 1975, KDNREP discovered
that releases of hazard-
ous substances
at the site had
contami-
nated Wilson
Creek.
KDNREP
removed some of the
drums from the surface as well as
some pollutants from Wilson
Creek. KDNREP pursued legal
actions against the site owner
from 1975 until 1977.
In 1977 the state ordered the
owner of the property to cease
improper dumping operations.
However, it was not until the
owner died later that same year
that the plant was finally closed.
State Requests Assistance
from EPA
In January 1979, at the request
of KDNREP, EPA investigated
and confirmed the presence of oil
and hazardous substances at the
Valley of the Drums site. Asa
result, in March 1979, EPA used
federal funds to stop runoff
continued on page 4
Site is proposed for the National Priorities List
Polluters perform additional emergency
cleanup actions
EPA improves earlier cleanup actions
m Public meeting is held
Site is listed final on NPL
Public meeting is held
EPA completes site investigation,
begins comprehensive cleanup
/ Comprehensive cleanup is completed
W Site is proposed for deletion from NPL
/ 30-year operation
and maintenance
program begins
' Site targeted for
deletion from NPL
1981 1982 1983
1986 1987 1988 1989
1992
Page 3
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Superfund At Work
Valley of the Drums, Bullitt County, KY
Fall 1992
Superfund Program Provides
Mechanism for EPA to Pursue Polluters
of Valley of the Drums
continued from page 3
contaminated with oils and
chemicals from entering Wilson
Creek.
Under the authority of the
Clean Water Act, emergency
actions performed early in 1979
by EPA included:
Securing, segregating, organiz-
ing, and marking surface
drums;
Constructing an underflow
dam in Wilson Creek to trap
floating contaminants for
removal;
Installing devices in Wilson
Creek to force soluble contami-
nants to the surface of the
water for removal;
Re-routing surf ace water
runoff to a detention lagoon
where it could be safely con-
tained before entering the
treatment system; and
Designing and installing a
limestone and carbon water
treatment system to decon-
taminate surface water before
releasing it into Wilson Creek.
These actions addressed the
most pressing threats to the
environment.
A Somber Lineup A seemingly endless parade of drums at the Valley of the Drums
site include many leaking hazardous chemicals. Contaminants spilled into the nearby
surface water. Little vegetation in the affected area survives.
Superfund Provides
Mechanism for Enforcing
Environmental Laws
Prior to 1980, federal and state
officials lacked clearly defined
authority for mnummummummn
holding polluters
accountable for
mdisoirninant
dumping.
Hence, tens of
thousands of
uncontrolled
In 1981, KDNREP contacted six
polluters who voluntarily re-
moved approximately 30 percent
of the waste remaining on the
surface of the site. In 1986, EPA
*""1 "" mma tmmmmmi entered into
negotiations
with four pollut-
ers to gain their
involvement in
hazardous waste
sites are now
The number of drums
the
of contamination
at the so
that further emergency
actions
necessary
comprehensive
site cleanup
activities.
However,
these negotia-
scattered across the United States. tions did not lead to an agree-
The initial removal activities at ment. Thus, EPA continued to
the Valley of the Drums site were perform site clean-up activities
conducted by EPA and KDNREP using Superfund monies.
prior to the existence of the Super- In October 1991, EPA settled
fund program. Once enacted, with four polluters for $ 1.8
Superfund provided a mechanism million of the costs associated
for EPA and KDNREP to identify with emergency and comprehen-
and pursue various polluters sive cleanup, thereby minimizing
responsible for contaminating the burden on the Superfund.
the site.
Page 4
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Superfund At Work
Valley of the Drums, Bullitt County, KY
Fall 1992
EPAfs Emergency Actions Alleviate
Immediate Threats and Pave Way for
Comprehensive Cleanup
EPA Addresses Worst
Threats Immediately
In addition to the enforcement
authority established by Super-
fund, the new law developed
methods to distinguish and treat
two classes of site contamination.
Site cleanup activities are catego-
rized as those which pose an
imminent threat to the environ-
ment, called emergency actions,
and those concerned with com-
prehensive, restorative site
Steep slopes and
severe soil erosion
from nŠ vegetation
caused additional
cleanup challenges
cleanup. At the Valley of the
Drums site, the Superfund pro-
gram started with emergency
actions and proceeded through
final comprehensive cleanup
activities.
Although early cleanup activi-
ties and drum removals were
performed in the late seventies by
KDNREP, EPA and polluters, the
number of drums and magnitude
of contamination at the site was
so great that further emergency
actions were deemed necessary.
EPA removed all remaining
surface drums and upgraded the
water treatment system installed
during the emergency actions of
1979. These 1981 emergency
activities satisfactorily reduced
continued on page 6
A Desolate Landscape A small portion of the 17,000 drums found on
the Valley of the Drums site are arranged in jumbled masses on the
sides of a barren landscape. A decade of improper hazardous waste
storage left segments of the topsoil unable to sustain vegetation,
increasing the problem of soil erosion along the steep manmade
inclines. Cleanup for the site included removal of drums, burying wastes
under a clay soil cap to prevent further surface contamination, and a
series of efforts to improve water in the area.
PageS
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Superfund At Work
Valley of the Drums, Bullitt County, KY Fall 1992
Valley of the Drums:
Contamination is Contained;
Cleanup Deemed a Success
continued from page 5
the threat to the environment. In
1983, Valley of the Drums was
placed on the National Priorities
List (NFL), EPA's roster of the
nation's most serious uncon-
trolled or abandoned hazardous
waste sites.
Inclusion on the NPL meant
that EPA would see to the
comprehensive cleanup and
restoration of the Valley of the
Drums site.
Valley of the Drums Undergoes
Comprehensive Treatment
Comprehensive cleanup
activities began in 1984 after a
study was conducted to identify
the full extent of contamination at
the site. This study confirmed
that discharge of contaminants
from the site was attributable to
surface water runoff.
A Complex Waterway At Risk
This photo shows the winding
pathway of the Ohio River.
Contaminants entered the Ohio's
tributary, Wilson Creek, and could
have had a disasterous effect had
cleanup actions not returned the
water to its unsullied state.
The comprehensive cleanup
plan, completed in 1986, was
designed to eliminate the remain-
ing contaminants threatening
Wilson Creek.
This plan was finalized in 1986,
and in 1987 comprehensive
cleanup activities began. These
actions involved:
Building six-foot-high security
fences with gates and posting
warning signs;
Installing a clay soil cap to
contain underground waste;
Excavating wastes and drums
and re-burying them under-
neath the cap;
Seeding the cap and surround-
ing areas with a mixture of
grasses and mulched straw;
Relining previously built
ditches;
Installing new drains; and
Installing additional monitor-
ing wells to gauge effectiveness
of the clay cap.
Severe soil erosion, created by
a lack of vegetation and the very
steep slopes cut by Mr. Taylor in
the northern and western sides of
the site, proved to be an addi-
tional challenge for the Superfund
team. The potential dangers of
continued erosion prompted EPA
to customize the clay cap with
terraces to ensure that it would
continue to function properly.
Page 6
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Superfund At Work
Valley of the Drums, Bullitt County, KY
Fall 1992
Continued Site Monitoring Is Essential
To Ensure Effective Operations
The monitoring program for
Valley of the Drums began in
the summer of 1988. An EPA
oversight team is ensuring that
all barriers remain intact and
that no fumes or liquids pen-
etrate the clay cap.
Quarterly visits to the site
are made to observe the visible
surface conditions of the site
and security features. Wilson
Creek and local ground water
are sampled regularly.
If no contamination is de-
tected, the cap is effectively
containing the contaminants.
To date, all cleanup measures
have been successful.
Framed by drums, members of the cleanup team use protective breathing
apparatus during monitoring activities. The site, which is protected by fences
to minimize direct contact, will be monitored regularly to ensure that the
many containment and cleanup measures continue to operate effectively.
EPA Anticipates Deletion of Valley of the Drums
From National Priorities List in 1992
Because the long-term cleanup
of this site has been successful,
the site was proposed for dele-
tion from the NPL in 1988. A
deletion record was prepared
that contains all documents and
materials cataloging site activities.
Site documents were placed in
a local repository and at the
EPA's Regional office. A notice
that the site is scheduled for
deletion was printed in a local
newspaper and in the Federal
Register, and the public was given where high levels of hazardous
an opportunity to comment on
the proposal to delete the site
from the NPL.
EPA did not receive any objec-
tions to the proposed deletion.
The site will be deleted from
the NPL based on the findings of
a five-year review, which is
expected to be completed later
this year.
A five-year review is always
conducted at Superfund sites
substances are present. These
reviews continue until contami-
nants are reduced to levels which
allow unrestricted property use.
If unexpectedly high levels of
contamination are found as a
result of periodic investigations,
EPA conducts additional testing
on-site and, if necessary, modifies
the cleanup method to be protec-
tive of ecological health.
W Environmental Protection Agency
Region 5 Ubrary (PL.12J) -y
//. West Jackson Boulevard ipth c.
°r IL 60604-3590 ' F'°c
Page 7
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Superfund At Work Valley of the Drums, Bullitt County, KY Fall 1992
Community Relations at
Valley of the Drums
Community relations at the
Valley of the Drums have been
very positive. Public meetings
were held in 1982 and in 1983 to
discuss comprehensive cleanup
alternatives at the site. Citizens
expressed appreciation for the
rapid attention EPA gave the site.
The only declaration of public
disapproval of site activities arose
when the State proposed on-site
incineration in 1979. The incin-
eration plan was discontinued at
that time and the clay cap
alternative was chosen instead.
EPA kept the public informed
throughout cleanup and contin-
ues to offer information to anyone
interested in the site.
Any questions concerning the
site should be directed to:
Community Relations Coordinator;
U.S. EPA, Region IV;
345 Courtland Street, NE;
Atlanta, GA 30365; (404) 347-3004.
For additional copies of this or other
Superfund At Work updates, contact the
National Technical Information Service,
U.S. Department of Commerce,
5285 Port Royal Road, Springfield, VA 22161,
telephone (703) 487-4650.
If you wish to be added to our mailing list
or to comment on this bulletin's content,
length or format,
please call (703) 603-8984
or send a letter to
Superfund At Work (5502G),
401 M Street SW,
Washington, DC 20460.
Success at
Valley of the
Drums
The drum removal effort
at the Valley of the Drums
site was one of the earliest
and largest in Superfund
history.
The expected deletion
of the site later this year
confirms EPA's ability to
effectively eliminate the
dangers that improper waste
disposal practices pose to
the environment.
In addition, EPA has
recovered $1.8 million from
polluters.
&EPA
United States Environmental Protection Agency
5502G
Washington, D.C. 20460
Official Business
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