FIFTH FIVE-YEAR REVIEW REPORT FOR
NATIONAL ELECTRIC COIL CO./COOPER INDUSTRIES SUPERFUND SITE
HARLAN COUNTY, KENTUCKY
V>EPA
AUGUST 2023
CAROLINE
FREEMAN
Prepared by
U.S. Environmental Protection Agency
Region 4
Atlanta, Georgia
Digitally signed by CAROLINE
FREEMAN
Date: 2023.08.23 17:46:15
-04'00'
Caroline Y. Freeman, Director
Superfund & Emergency Management Division
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Table of Contents
LIST OF ABBREVIATIONS AND ACRONYMS iv
I. INTRODUCTION 1
Site Background 1
FIVE-YEAR REVIEW SUMMARY FORM 2
II. RESPONSE ACTION SUMMARY 4
Basis for Taking Action and Response Actions 4
Status of Implementation 6
Systems Operations/O&M 1 1
III. PROGRESS SINCE THE PREVIOUS REVIEW 12
IV. FIVE-YEAR REVIEW PROCESS 13
Community Notification, Community Involvement and Site Interviews 13
Data Review 14
Site Inspection 20
V. TECHNICAL ASSESSMENT 20
QUESTION A: Is the remedy functioning as intended by the decision documents9 20
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the
time of the remedy selection still valid9 21
QUESTION C: Has any other information come to light that could call into question the
protectiveness of the remedy9 22
VI. ISSUES/RECOMMENDATIONS 23
OTHER FINDINGS 24
VII. PROTECTIVENESS STATEMENT 25
VIII. NEXT REVIEW 25
APPENDIX A - REFERENCE LIST A-1
APPENDIX B - CURRENT SITE STATUS B-l
APPENDIX C - SITE CHRONOLOGY C-l
APPENDIX D - 1989-1991 RESPONSE ACTIONS D-l
APPENDIX E - RESTRICTIVE COVENANTS E-l
APPENDIX F - PRESS NOTICE F-l
APPENDIX G - INTERVIEW FORMS G-l
APPENDIX H - DATA REVIEW SUPPLEMENTS H-l
APPENDIX I - SITE INSPECTION CHECKLIST 1-1
APPENDIX J - SITE INSPECTION PHOTOS J-l
APPENDIX K - DETAILED ARARS REVIEW TABLES K-l
APPENDIX L - SCREENING-LEVEL AND VAPOR INTRUSION RISK REVIEW L-l
Tables
Table 1: Groundwater COCs and Cleanup Goals 6
Table 2: Remedy Air Emission Performance Standards 6
Table 3: Summary of Planned and/or Implemented Institutional Controls 8
Table 4: Protectiveness Determination/Statement from the 2018 FYR Report 12
Table 5: Status of Recommendations from the 2018 FYR Report 12
Table 6: Status of Recommendation from the 2021 FYR Addendum 13
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Table 7: Summary of Stack Air Emissions, 2018 to 2021 18
Table C-l: Site Chronology C-l
Table D-1: EPA Action Levels - 1991 Removal Action D-l
Table H-l: Groundwater Monitoring Network H-l
Table H-2: On-Site Well Exceedances - Semi-Annual Groundwater, 2018 to 2022 H-l
Table H-3: Off-Site Well Exceedances - Semi-annual Groundwater Sampling Events, 2018 to 2022. H-2
Table K-l: Groundwater ARARs Review K-l
Table L-l: Groundwater Screening-Level Risk Review L-2
Table L-2: Stack Emission Rates Risk Review L-2
Table L-3: Vapor Intrusion Assessment L-3
Figures
Figure 1: Site Vicinity Map 3
Figure 2: Institutional Control Map 10
Figure 3: Detailed Site Map 19
Figure D-l: Removal Action Soil Excavation Boundaries D-2
Figure E-1: Environmental Covenant (May 2, 2018) E-1
Figure E-2: Amended Environmental Covenant, September 27, 2017 E-14
Figure H-l: Recovery Well CMW-5-2A VOC Concentrations Versus Time H-3
Figure H-2: Recovery Well R-2 VOC Concentrations Versus Time H-3
Figure H-3: Recovery Well CMW-5-11 VOC Concentrations Versus Time H-4
Figure H-4: Interceptor Trench/Sump VOC Concentrations Versus Time H-4
Figure H-5: Monitoring Well CMW-7 VOC Concentrations Versus Time H-4
Figure H-6: Monitoring Well CMW-12 VOC Concentrations Versus Time H-5
Figure H-7: Monitoring Well CMW-85 VOC Concentrations Versus Time H-5
Figure H-8: Cumulative VOC Recovery H-6
Figure H-9: Soil Boring/Temporary Assessment Well Locations Map H-6
Figure H-10: TCE Concentrations in Soil H-6
Figure H-1 1: Groundwater TCE Isoconcentration Map H-7
Figure H-l2: Indoor Air and Sub-Slab Sampling Locations H-8
Figure H-l3: Statistical Analyses H-9
in
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LIST OF ABBREVIATIONS AND ACRONYMS
ARAR
Applicable or Relevant and Appropriate Requirement
BRA
Baseline Risk Assessment
C
Celsius
CERCLA
Comprehensive Environmental Response, Compensation, and Liability Act
CFR
Code of Federal Regulations
COC
Contaminant of Concern
DCE
Dichloroethene
EPA
United States Environmental Protection Agency
ESD
Explanation of Significant Differences
FS
Feasibility Study
FYR
Five-Year Review
g/sec
Grams per Second
HQ
Hazard Quotient
IUR
Inhalation Unit Risk
KAR
Kentucky Administrative Regulations
KDEP
Kentucky Department of Environmental Protection
KDWM
Kentucky Department of Waste Management
KPDES
Kentucky Pollutant Discharge Elimination System
KYDOT
Kentucky Department of Transportation
lb/hr
Pounds per Hour
MCL
Maximum Contaminant Level
mg/kg
Milligrams per Kilogram
mg/L
Milligrams per Liter
MNA
Monitored Natural Attenuation
|ig/day
Micrograms per Day
|ig/L
Micrograms per Liter
|ig/m3
Micrograms per Cubic Meter
NCP
National Contingency Plan
NEC
National Electric Service Company
NPL
National Priorities List
O&M
Operation and Maintenance
OU
Operable Unit
PCB
Polychlorinated Biphenyl
PCE
T etrachl oroethene
ppbv
Parts per Billion by Volume
PRP
Potentially Responsible Party
RAO
Remedial Action Objective
RI
Remedial Investigation
ROD
Record of Decision
RPM
Remedial Project Manager
RSL
Regional Screening Level
SB
Soil Boring
TAW
Temporary Assessment Well
TCE
T ri chl oroethylene
TCLP
Toxicity Characteristic Leaching Procedure
UAO
Unilateral Administrative Order
UU/UE
Unlimited Use and Unrestricted Exposure
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Vapor Intrusion Screening Level
Volatile Organic Compound
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I. INTRODUCTION
The purpose of a five-year review (FYR) is to evaluate the implementation and performance of a remedy
to determine if the remedy is and will continue to be protective of human health and the environment.
The methods, findings and conclusions of reviews are documented in FYR reports such as this one. In
addition, FYR reports identify issues found during the review, if any, and document recommendations to
address them.
The U.S. Environmental Protection Agency is preparing this FYR pursuant to the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) Section 121, consistent with the
National Contingency Plan (NCP) (40 Code of Federal Regulations (CFR) Section 300.430(f)(4)(ii)) and
considering EPA policy.
This is the fifth FYR for the National Electric Coil Co./Cooper Industries Superfund site (the Site). The
triggering action for this policy review is the completion date of the previous FYR. The FYR has been
prepared because hazardous substances, pollutants or contaminants remain at the Site above levels that
allow for unlimited use and unrestricted exposure (UU/UE).
The Site consists of a single, site wide operable unit (OU). This FYR Report addresses the OU.
EPA remedial project manager (RPM) Craig VanTrees led the FYR. Participants included EPA
community involvement coordinator Tonya Spencer-Harvey, EPA human health risk assessor
Adam Friedman, EPA hydrologist Bill O'Steen, Christoph Uhlenbruch and Larry Tackett with the
Kentucky Department of Environmental Protection (KDEP), and Lauren Johnson and Kirby Webster
with EPA FYR contractor Skeo. The potentially responsible parties (PRPs) - McGraw-Edison
Company/Cooper Industries, Inc. (Cooper Industries), Treen Land Company and National Electric
Service Company (NEC) - were notified of the initiation of the FYR. The review began on 10/3/2022.
Site Background
The 3.5-acre Site is located on Day Hoit Drive (formally known as Old U.S. Route 1 19), next to the
Cumberland River in the town of Dayhoit in Harlan County, Kentucky (Figure 1). From 1951 to 2010,
several industries (including the National Electric Coil Company, now NEC) operated on site.
Operations included a rebuilding and remanufacturing facility for coal mining and related industrial
equipment, electrical motor repair work and limited rebuilding of hydraulic systems for the coal
industry. The operations resulted in groundwater and soil contamination with trichloroethylene (TCE),
polychlorinated biphenyls (PCBs) and heavy metals.
The Site includes a former manufacturing facility, which consists of a main plant building, two smaller
buildings, an asphalt parking lot and a grass-covered riverbank area. The Site also encompasses the areal
extent of shallow and intermediate groundwater contamination. In 2010, the property was purchased; it
is used as an automobile salvage yard. The EPA anticipates that the Site will remain in commercial and
industrial use. The surrounding area will likely remain in residential use. Holiday Acres Mobile Home
Park borders the Site to the south. A Kentucky Utilities Company electrical substation borders the Site
to the north. The site property is fenced on all sides and has security cameras installed.
Three water-bearing units underlie the Site: the shallow alluvial aquifer and the intermediate and deeper
zones of the bedrock aquifer. All three units are contaminated. The alluvium generally contains
groundwater under unconfined conditions at depths averaging 20 feet below ground surface.
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Groundwater flow in the shallow aquifer is to the east toward the Cumberland River and away from the
main plant building and the residential areas south of the Site. Groundwater in the bedrock aquifer flows
to the southwest, toward the residential areas. Groundwater in the bedrock aquifer generally occurs
under confined conditions within the bedrock's secondary fractures and faults. Groundwater flow in the
bedrock does not appear to be influenced by the directional flow of the Cumberland River. The bedrock
aquifer is the drinking water aquifer in the area, while the shallow aquifer is not used for drinking water.
In 1989, after the discovery of contamination, residential groundwater users in areas whose wells were
contaminated or at risk of future contamination were connected to the municipal water supply system.
The Harlan County public water supply intake is upstream of the Site, on the Cumberland River.
Institutional controls have been implemented on some properties affected by the groundwater plume to
restrict groundwater use and well placement. The PRPs are still working to place institutional controls
on the remaining properties.
The Site is located in the floodplain of the Cumberland River. The river flows from north to south next
to the Site and serves as a discharge point for surface water drainage leaving the Site.
Appendix A lists the resources referenced during the development of this FYR Report. Appendix B
provides site status information. Appendix C provides a chronology of major site events.
FIVE-YEAR REVIEW SUMMARY FORM
[
SITE IDEYMI l( ATION
Site Name: National Electric Coil Co./Cooper Industries
EPA ID: KYD985069954
Region: 4
State: Kentucky City/County: Dayhoit/Harlan
SITE S I A I I S
NPL Status: Final
Multiple OUs?
No
Lead agency: EPA
Has the Site achieved construction completion?
Yes
REVIEW S I A I I S
Author name: Craig VanTrees
Author affiliation: EPA with support provided by Skeo
Review period: 10/3/2022 - 7/31/2023
Date of site inspection: 11/16/2022
Type of rev iew: Policy
Review number: 5
Triggering action date: 9/20/2018
Due date (fiveyears after triggering action date): 9/20/2023
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Figure 1: Site Vicinity Map
National Electric Coil Co./Cooper
Industries Superfund Site
Community of Dayhoit, Harlan County, Kentucky
1
100
-1—
200
—I—
300
—I—
400
Disclaimer This map and any boundary lines within the map are approximate and subject
to change. The map is not a survey The map is for informational purposes only regarding
the EPA's response actions at the Site. Map image is the intellectual property of Esri and
is used herein under license. Copynght © 2020 Esri and its licensors. All rights reserved.
Sources: Esri. Esri Community Maps Contributors, VGIN, © OpenStreetMap, Microsoft,
Esn, HERE, Garmin, SafeGraph, GeoTechnologies, Inc, METI/NASA, USGS, EPA, NPS,
US Census Bureau, USDA, Maxar, Microsoft and the EPA's, Office of Mission Support;
Data Steward: the EPA's, Office of Land and Emergency Management - NPL Superfund
Site Boundaries (EPA Public 2022).
^Skeo
Last Modified: 2/21/2023
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II. RESPONSE ACTION SUMMARY
Basis for Taking Action and Response Actions
From 1951 to 1967, NEC reportedly cleaned electrical equipment in a 1,000-gallon vat of TCE.
Periodically, the vat was cleaned, and the liquid solvent and oils reportedly flowed overland and/or
through a drainage system to the Cumberland River. Sludges collected from the vat, as well as debris
containing high concentrations of heavy metals, were reportedly disposed of along the riverbank. From
1967 to 1987, various other substances, including methylene chloride and a non-solvent cleaner, were
used to clean equipment.
In February 1989, the KDEP sampled the community well at the Holiday Acres Mobile Home Park as
well as surrounding private drinking water wells. Analyses of the samples indicated the presence of
volatile organic compounds (VOCs) at concentrations above national primary drinking water regulation
maximum contaminant levels (MCLs) in 12 of the wells. Several interim response actions, including a
removal action in 1991, occurred on site between 1989 and 1991. Appendix D of this FYR Report
provides more information.
Initial studies at the Site prior to its listing on the Superfund program's National Priorities List (NPL)
indicated that contaminants had impacted soil and sediments adjacent to the Site as well as the
groundwater beneath the Site and downgradient of the Site. The EPA proposed the Site for listing on the
NPL in July 1991. The EPA finalized the Site's listing on the NPL in October 1992.
The Site's remedial investigation and feasibility study (Rl/FS) and associated site studies were
conducted under a 1992 Administrative Order on Consent between PRP Cooper Industries and the EPA.
The 1996 R1 indicated that groundwater in both aquifers - the shallow alluvial aquifer, and the
intermediate and deeper zones of the bedrock aquifer - are impacted by site-related contaminants.
Sampling of on-site subsurface soil, collected following the 1991 removal action, indicated that the
contaminants remaining no longer posed a leaching threat to groundwater. Soil samples collected from
the Holiday Acres Mobile Home Park indicated that soils had not been impacted significantly by
contaminants. Sediment samples indicated the presence of site-related contaminants, but they were
limited to the immediate vicinity of the outfall.1
As part of the Rl/FS, the baseline risk assessment (BRA) evaluated exposures to chemicals through
ingestion, dermal contact and inhalation of groundwater, on-site subsurface soils and off-site surface
soils by residents and workers. Additionally, ingestion of and contact with sediment and ingestion of
fish by residents were considered as possible exposure pathways. The BRA did not evaluate on-site
surficial soils because all identified site soils (including subsurface soils) that exceeded EPA action
levels were excavated during the 1991 removal action and the excavation areas were backfilled with
clean soil. The BRA also did not evaluate surface water because of the uncertainties associated with
determining the origin of detected chemicals. The BRA concluded that the primary health risk posed by
the Site was through the groundwater pathway, because cumulative cancer risks exceeded the upper
bound of the EPA's acceptable risk range (1 x 10"4) and the noncancer risks exceeded the hazard
quotient (HQ) of 1.0 for both future child and future adult residents. Risks associated with the ingestion
of fish also exceeded the 1 x 10"4 guideline for the current residential scenario due to the levels of PCBs
1 PCBs and other semi-VOCs were also found at the outfall, but they were also detected both upstream and downstream of
the Site. This finding indicates that there arc sources of these contaminants other than NEC upstream of the Site. The
presence of these contaminants in nearby river sediments is most likely due to general pollution of the river from a variety of
unknown origins.
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detected in fish samples. However, PCB levels detected in fish samples were comparable to the
background levels for fish found in the Cumberland River and other Kentucky waters.
The EPA issued an Interim Record of Decision (ROD) in September 1992 to minimize VOC plume
migration in the bedrock groundwater until a final site remedy was selected. The 1992 Interim ROD did
not identify remedial action objectives (RAOs). The remedial action was selected to: (1) prevent future
groundwater plume migration in the bedrock aquifer; and (2) initiate groundwater restoration prior to the
completion of the RI/FS and post-RI/FS activities. The EPA issued a ROD in April 1996 to address
groundwater contamination beneath the Site. The 1996 ROD did not identify RAOs. The remedial action
was selected to: (1) prevent further groundwater plume migration through the bedrock aquifer and the
alluvial aquifer; and (2) continue groundwater restoration activities as specified in the 1992 Interim ROD.
The components of the remedy selected in the 1992 Interim ROD and detailed further in the
1996 ROD included:
• Extraction of contaminated groundwater from the Site's alluvial and bedrock aquifers.
• Treatment of contaminated groundwater using an air stripper tower.
• Discharge of treated groundwater to the Cumberland River following Kentucky's pollutant
discharge elimination system (KPDES) requirements.
• Emissions controls and catalytic oxidation on the air stream leaving the air stripping tower.
The EPA issued an Explanation of Significant Differences (ESD) in July 1997. It modified the remedy
selected in the 1996 ROD. The approach for contaminated groundwater recovery from the alluvial
aquifer was changed from a series of small extraction wells to use of a single interceptor trench. The
EPA issued a second ESD in February 201 1 that further modified the groundwater remedy. RAOs
described in the 201 1 ESD were to: (1) control risks posed by direct contact with groundwater; and
(2) minimize migration of contaminants in groundwater. The 201 1 ESD documented the decision to
include institutional controls as part of the groundwater remedy and to remove the catalytic oxidizer
from the groundwater pump-and-treat system.
Table 1 and Table 2 list the contaminants of concern (COCs) and performance standards from the
1996 ROD for groundwater and remedy stack emissions, respectively. The 1996 ROD also established
performance standards for discharge of treated groundwater to surface water that are monitored under
the requirements of a KDPES permit (the Systems Operations/Operation and Maintenance [O&M]
section of this FYR report provides more information). The 1996 ROD also specified temporary air
emission limits at the fence line of the Holiday Acres Mobile Park and at a weather station on site as
performance standards for cis-1,2-dichloroethene (DCE), TCE and vinyl chloride (5 micrograms per
cubic meter [|ig/m3]). Continuous air monitoring was conducted for several years following the startup
of the groundwater remediation system in 1993. After a period of no V OC detections in the area,
ambient air monitoring was discontinued with the approval of the EPA.
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Table 1: Groundwater COCs and Cleanup Goals
Groundwater COC
ROD Cleanup Goal (fi
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process of air stripping. Air stripper off-gases are discharged into the atmosphere via a 60-foot-tall
air stack.
The 1996 ROD included temporary, health-based site-specific air emissions limits for vinyl chloride,
TCE and cis-l,2-DCE (5 |ig/m3).
In September 2001, the Kentucky Division of Waste Management (KDWM) recommended updating site
soil action levels to site-specific risk-based levels based on residential exposure. The revised soil action
level (0.126 milligram per kilogram [mg/kg] total PCBs) was the risk-based cleanup guideline for soils
outside of the fence line. A few of the sampling results exceeded the proposed guideline. PRP Cooper
Industries agreed to perform a surface soil removal action to achieve the revised action level. In
October 2001, PRP contractors removed 170 tons of soil and took it off site for disposal.
In 201 1, the air stripping tower was replaced with a low-profile air stripper, an insulated building was
built to house the new air stripper, the catalytic oxidation unit was removed, and the exhaust duct was
re-piped. This change was appropriate because the off gases from the air stripper were below action
levels and no longer required treatment in order to comply with the air emissions standards in the
1996 ROD and established by the KDEP (Table 2). Treated water continues to be discharged to the
Cumberland River in accordance with KPDES requirements for the Site.
The 2013 FYR Report and 2018 FYR Report identified that a significant source of contamination may
still be present near well R-1 and recommended that the PRP investigate the possible source of
contamination in the shallow alluvial aquifer. The PRP conducted a source area investigation in
July 2021. In 2022, the PRP submitted the Source Area Assessment Report to the EPA. The EPA has
reviewed the report and recommends additional investigation of conditions in the unsaturated zone and
groundwater beneath the building. The EPA will review potential remedial actions in the future. The
Data Review section of this FYR Report provides more information.
The 2013 FYR Report also identified that there was potentially an unacceptable vapor intrusion risk and
noncancer hazard on site due to long-term exposure to TCE in indoor air and recommended that the PRP
investigate the vapor intrusion pathway. The PRP conducted two rounds of indoor air and sub-slab
sampling in 2021. The results of the sampling showed that there was no unacceptable risk at that time
(the Data Review section of this FYR Report provides more information). In 2022, the PRP submitted
the Vapor Intrusion Assessment Report to the EPA. The EPA agrees that no further vapor intrusion
investigation/monitoring is needed at this time. If site conditions change in the future, then vapor
intrusion investigations/monitoring should be conducted.
Institutional Control Review
The 201 1 ESD modified the remedy selected in the 1996 ROD to require institutional controls, in the
form of a restrictive covenant or other enforceable institutional controls, as part of the groundwater
remedy for the Site. In addition to restricting groundwater use on site (parcel 56), similar institutional
controls will be needed for three adjacent parcels where the groundwater contamination has migrated
(Figure 2: Parcel 53 (Kentucky Department of Transportation [KYDOT] property). Parcel 54
(residential property) and Parcel 55 (Holiday Acres Mobile Home Park property). The objective of the
institutional controls is to ensure that future users (people who have the potential to install a
groundwater well) do not come in contact with contaminated groundwater in the alluvial aquifer and
intermediate and deeper zones of the bedrock aquifer beneath the Site until the drinking water aquifer
(the bedrock aquifer) meets cleanup standards and is returned to beneficial use.
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The restrictive covenants on Parcel 53 (KYDOT property) and Parcel 54 (residential property) have
been completed (Figure 2). The PRP is working with the property owners of the remaining parcels to
implement covenants to restrict the use of the groundwater for drinking water purposes within the
footprint of the groundwater plume. Residential groundwater users in areas with contamination have
been connected to the municipal water supply system since 1989. The covenants outline the
responsibilities of the current and future property owners to ensure the groundwater access for drinking
water purposes is restricted. PRP Cooper Industries will be responsible for monitoring the institutional
controls and for costs of implementation and maintenance of the institutional controls. The soil
contamination was excavated below detection levels. Therefore, institutional controls for soils were not
required in decision documents. However, recent source investigations underneath the building have
identified more soil contamination. Given that there is not a completed exposure pathway because of the
building foundation, this is not a current protectiveness issue. However, additional sampling may
indicate the need for soil institutional controls. Table 3 summarizes the institutional controls at the Site.
The implemented restrictive covenants are included in Appendix E.
Table 3: Summary of Planned and/or Implemented Institutional Controls
Media, Engineered
Controls, and Areas
That Do Not
Support IJIJ/UE
Based on Cu rrent
Conditions
ICs
Needed
ICs Called
for in the
Decision
Documents
Impacted
Parcel(s)
IC
Objective
Title of IC Instalment
Implemented and Date
(or planned)
Yes
Yes
53a, 54b (see
Figure 2).
Groundwater
Restrict use of
groundwater for
drinking and other
domestic or
industrial uses.
Restrict disturbing
groundwater
monitoring wells
without prior
approval from
the EPA.
Restrict actions
that arc
reasonably likely
to create a risk of
migration of
substances
covered under the
ROD and
Unilateral
Administrative
Order (UAO).
Amended Environmental
Covenant.
September 27, 2017
(Parcel 53)
Environmental Covenant
May 2, 2018 (Parcel 54)
Yes
Yes
55°, 56d(see
Figure 2).
• Restrict use of
groundwater for
drinking and other
domestic or
industrial uses.
Planned
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Media, Engineered
Controls, and Areas
That Do Not
Support UU/lJE
Based on Current
Conditions
ICs
Needed
ICs Called
for in the
Decision
Documents
Impacted
Parcel(s)
IC
Objective
Title of IC Instrument
Implemented and Date
(or planned)
Soil
Yes
No
56d(see
Figure 2).
• Prevent contact with
contaminated soil.
Planned
Notes:
a. Parcel 53: KYDOT property.
b. Parcel 54: Residential property.
c. Parcel 55: Holiday Acres Mobile Home Park property.
d. Parcel 56: NEC/Cooper Industries/Pennington property.
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: 2: Institutional Control Ma
Parcel Subject to 2017 Amended Environmental
:::::::: Covenant Shallow Alluvial Aquifer VOC Plume (2022)
POO Parcel Subject to 2018 Environmental Covenant CJj Bedrock Aquifer - Deeper Zone VOC Plume (2022)
Note: The bedrock aquifer - intermediate zone VOC plume was not
included due to the lack of monitoring wells.
National Electric Coil Co./Cooper
Industries Superfund Site
Community of Dayhoit, Harlan County, Kentucky
Parcel
Disclaimer This map and any boundary lines within the map are approximate and
subject to change. The map is not a survey. The map is for informational purposes
only regarding the EPA's response actions at the Site Map image is the intellectual
property of Esrl and is used herein under license Copyright © 2020 Esri and its
licensors. All rights reserved Sources: Esri, Esri Community Maps Contributors.
VGIN, © OpenStreetMap. Microsoft, Esri, HERE, Garmin, SafeGraph,
GeoTechnologies, Inc. METI/NASA, USGS, EPA, NPS, US Census Bureau, USDA,
Maxar, Microsoft, the 2013 Five-Year Review Report, the EPA's, Office of Mission
Support; Data Steward: the EPA's, Office of Land and Emergency Management -
I NPL Superfund Site Boundaries (EPA Public 2022) and Response to Comments on
1 000 Feet 20^2 First Semi-Annual Monitoring Report for the National Electric Coil Co./
Cooper Industries Superfund Site.
10
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Systems Ooeratioiis/Q& M
Site O&M activities have been conducted since 1999 in accordance with the 1996 ROD. Total Electric
in Dayhoit, Kentucky, conducts O&M activities at the Site on behalf of PRP Cooper Industries. O&M
activities are conducted in accordance with the Site's O&M Plan, which was updated in August 2012.
The update reflects changes in the treatment system, required by the 2011 ESD, to address the
replacement of the air stripping tower with a low-profile air stripper and the removal of the catalytic
oxidation unit. Current O&M activities include:
• General housekeeping and weed control.
• Maintenance of the fence that surrounds the facility.
• Inspection of the condition of the groundwater monitoring wells.
• Maintenance and upkeep of the pumping wells.
• Maintenance and upkeep of the low-profile air stripper.
• Quarterly monitoring of the water system discharge in accordance with KPDES requirements.
• Monitoring the quality of the system's air discharge.
Total Electric inspects the groundwater remediation system weekly. Shield Environmental Associates, a
contractor to the PRP, provides regular maintenance and oversees repairs needed to the system. Shield
Environmental Associates also coordinates water and air sampling and conducts semi-annual
groundwater monitoring of on-site and off-site wells. Table H-l describes the groundwater monitoring
network. In July 2006, the EPA approved a change for annual, rather than semi-annual, sampling of
wells that have historically had low VOC concentrations. These wells include CMW-85, CMW-6.
CMW-13, CMW-9, CMW-5-10, CMW-5-0, BH-0 and BH-1 (Figure 3). The change was approved with
the understanding that if a significant trend or increase in COC concentrations is observed above the
MCLs in any of the above-mentioned wells, then the sampling frequency will be increased back to a
semi-annual basis. Semi-annual groundwater reports are prepared and submitted to the EPA and the
KDEP summarizing the performance of the pump-and-treat system and related O&M activities.
During the first six months of 2022, the groundwater recovery system was not operational due to a pump
failure. Total Electric discovered that the pump that transfers water from the equalization tank to the air
stripper was not functioning. The pump was removed and sent to an electrical subcontractor to be
rebuilt. In May 2022, the rebuilt pump was reinstalled. The pump operated for about two weeks before
an electrical malfunction in the system caused the pump to burn out and required a second rebuild.
The rebuilt pump was received and reinstalled in July 2022 and the system has been operating as
designed since.
The discharged groundwater is monitored to demonstrate compliance with KPDES requirements. The
discharge is currently monitored under the requirements set forth in KPDES Permit No. KY0093149.
The current permit expires on December 3 1, 2027. A renewal application was filed with the Kentucky
Division of Water on May 17, 2022, and the application was approved on November 4, 2022. The
permitted groundwater withdrawal rate of 250 gallons per minute remains unchanged. According to the
2022 First Semi-Annual Monitoring Report, the current effluent limitations have been achieved
throughout the reporting period. The KDEP has not established air emission limits for the treatment
system and does not require a permit. The 1996 ROD established performance standards with limitations
on the discharge of TCE, cis-l,2-DCE and vinyl chloride into the air. The point of compliance for the
emission rate standards is the discharge end of the air stripper exhaust stack. Air monitoring is
performed on a quarterly basis in conjunction with the KPDES discharge monitoring program.
1 1
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III. PROGRESS SINCE THE PREVIOUS REVIEW
This section includes the protectiveness determination and statement from the 2018 FYR Report (Table 4)
and 2021 FYR Addendum as well as the recommendations from the 2018 FYR Report (Table 5) and
2021 FYR Addendum (Table 6) and the status of those recommendations.
Table 4: Protectiveness Determination/Statement from the 2018 FYR Report
OIJ #
Protectiveness
Determination
Protectiveness Statement
Sitewide
Protectiveness Deferred
A protectiveness determination of the remedy cannot be made
at this time until further information is obtained. There is
potentially an unacceptable vapor intrusion risk and no il-
ea nccr hazard onsite due to long-term exposure to TCE in
indoor air. Further information will be obtained by
investigating the vapor intrusion pathway. The EPA site team
will review the workplan to ensure all vapor intrusion
concerns arc met. It is expected that this action will take
approximately three years to complete, at which time a
protectiveness determination will be made.
The 2021 FYR Addendum revised the protectiveness statement as follows:
The ongoing remedy at the National Electric Coil Site is protective of human health and the environment
in the short-term, because the results of the sub-slab soil gas and the indoor air samples collected show
that there is currently no unacceptable risk via the vapor intrusion pathway. However, to be protective
in the long term, the sampling program should be revised to include monitoring the vapor intrusion
pathway for site related COCs, including sub-slab gas, indoor air and ambient air samples.
Table 5: Status of Recommendations from the 2018 FYR Report
OIJ
#
Issue
Recommendations
Current
Status
Current Implementation
Status Description
Completion
Date (if
applicable)
1
A very large number
of derelict/salvage
vehicles make
sampling and other
investigation of site
conditions difficult
to impossible.
Remove or
reposition
derelict/salvage
vehicles to make
access to wells and
areas of concern
manageable.
Completed
Derelict/salvage vehicles that
were present in the area of
concern and preventing access to
wells have been moved. Based
on observations at the FYR site
inspection, all wells and areas of
concern arc accessible.
11/16/2022
1
A significant source
of contamination
may still be present
near well R-l.
Investigate the
possible source of
contamination and
evaluate the need
for optimizing the
water treatment
system.
Ongoing
The PRPs submitted a draft
investigation of source
contamination. Upon review the
EPA determined that an
additional investigation is
needed, and the PRPs concurred.
The EPA will work with the PRP
to determine next steps and/or if
the remedy needs to be
optimized.
Not applicable
1
Institutional controls
for groundwater on
properties where
contamination exists
and has migrated.
Complete
restrictive
covenants on
properties affected
by groundwater
contamination.
Ongoing
The PRPs and the EPA are
continuing to attempt to
complete restrictive covenants
on affected properties.
Not applicable
12
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OIJ
#
Issue
Recommendations
Current
Status
Current Implementation
Status Description
Completion
Date (if
applicable)
1
There is potentially
an unacceptable
vapor intrusion risk
and noncancer
hazard on site due to
long-term exposure
to TCE in indoor air.
The PRP should
investigate the
vapor intrusion
pathway. The EPA
site team will
review the
workplan to ensure
all vapor intrusion
concerns arc met.
Completed
The PRP completed a vapor
intrusion study in April 2021.
The oversight party has
completed the vapor intrusion
assessment. The results of the
sub-slab soil gas and indoor air
samples collected show that
there is not a complete vapor
intrusion pathway currently.
7/1/2021
1
Benzene has been
detected in
groundwater samples
at concentrations
above the 5 ng/L
primary drinking
water standard.
Consider adding
benzene as a site
groundwater COC.
Under
Discussion
The EPA will continue to
monitor benzene to determine if
it should be a COC.
Not applicable
Table 6: Status of Recommendation from the 2021 FYR Addendum
OIJ
#
Issue
Recommendations
Current
Status
Current Implementation
Status Description
Completion
Date (if
applicable)
1
Elevated TCE
concentration in the
sub-slab vapor
samples.
Update the existing
sampling program
to include
monitoring the
vapor intrusion
pathway for site-
related COCs.
including sub-slab,
indoor air and
ambient air
samples.
Ongoing
The existing sampling program
has not been updated to include
monitoring the vapor intrusion
pathway because there is
currently not a complete vapor
intrusion pathway. However, the
PRPs continue to investigate
source contamination underneath
the building. Depending on the
outcome of any activities related
to the source investigation, vapor
intrusion may need to be
revaluated.
Not Applicable
IV. FIVE-YEAR REVIEW PROCESS
Community Notification. Community Involvement and Site Interviews
The EPA issued an online news release on October 19, 2022, to announce that the FYR was underway.
A copy of the news release is available online at https ://www. epa. gov/newsrel eases/epa-revi ew-
cleanups-45-southeast-superfund-sites and is included in Appendix F. The results of the review and the
completed FYR Report will be made available on the EPA's site profile page:
http://www.epa.gOv/superflnid/n.atioiial-electric-coil-cooper-in.dustries. The EPA's site profile page can
also be accessed online at the Site's information repository, Bryan W. Whitefield Jr. Public Library,
located at 107 North 3rd Street in Harlan, Kentucky 40831.
During the FYR process, interviews were conducted to document any perceived problems or successes
with the remedy that has been implemented to date. The interviews are summarized below and included
in Appendix G. Additionally, interview forms were mailed to the property owner and two residents who
have monitoring wells located on their property. No responses were received.
13
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Michael Morris with Shield Environmental Associates (PRP contractor) stated that though the
groundwater impacts at the Site have become asymptotic, the system continues to create a cone of
depression in the intermediate and deep aquifers and the interceptor trench appears to remain effective in
preventing contaminants in the shallow aquifer from migrating off site or to the Cumberland River.
Jeffrey P. Allen with Cooper Industries is not aware of any complaints or inquiries from residents since
implementation of the cleanup and to his knowledge there have been no adverse effects of the Site on
the surrounding community over the past five years.
Larry Tackett with the KDEP believes that the usage of the property as a salvage yard may be negatively
impacting the Site in unknown ways. For example, the salvaged vehicles could be leaking various fluids
to the subsurface, possibly slowing down or causing the need to alter the remedy.
Data Review
This FYR evaluates groundwater monitoring data collected during semi-annual monitoring events as
well as stack air emissions results from 2018 through the first half of 2022.2 It also evaluates
groundwater monitoring and soil samples collected in 2021 for the Source Area Assessment Report and
indoor air and sub-slab soil gas samples collected in 2021 for the V apor Intrusion Pathway Assessment
Report. Overall findings during this FYR period include:
• TCE, vinyl chloride (shallow alluvial and intermediate bedrock zone), cis-1,2-DCE and benzene
(intermediate bedrock zone) were detected on site above MCLs during this review period. Vinyl
chloride (intermediate and deep bedrock zone), TCE and cis-1,2-DCE (deep bedrock zone) were
detected above their MCLs off site during this review period. 1,1-DCE, trans-1,2-DCE and
1,1,2,2-tetrachloroethane were not detected above MCLs during this review period.
• Data indicates that the groundwater pump-and-treat system appears to generally control the
migration of contaminants off site. Prior to June 2019, VOCs had not been detected above MCL
levels in off-site downgradient well CMW-85. In June 2019, TCE was detected at a
concentration of 10.5 micrograms per liter (|ig/L) (cleanup goal = 5 |ig/L). CMW-85 should
continue to be monitored to assess contaminant migration.
• Long-term monitoring data indicates a generalized decrease of VOC contamination in both
aquifers over time. However, concentrations of several COCs remain above MCLs (shallow
alluvial aquifer and intermediate and deep zones of the bedrock aquifer) and appear to be
persistent at a few wells, indicating that contaminant mass sourcing to groundwater remains.
Statistical analyses indicate contaminant concentrations in most wells that have a trend are
expected to attain cleanup goals within the next seven years with the exception of cis-1,2-DCE in
R-2 and CMW-5-11A which are estimated to meet cleanup goals in 2043 and 2037, respectively.
Site COCs were detected in soil and groundwater beneath the plant building during the source
area investigation. More investigations are being planned and potential alternative remedial
activities are being investigated.
• The results of the indoor air samples collected show that there is no current unacceptable risk,
and no further vapor intrusion investigation/monitoring is needed at this time. However, results
of the sub-slab soil gas screening level investigation indicate that if the building were enclosed,
the vapor intrusion pathway should be reevaluated.
2 The treatment system was not in operation from January 2022 through June 2022 due to a pump failure. Therefore, no air
emissions samples were collected during this time.
14
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Semi-Annual Groundwater Monitoring
PRP Cooper Industries conducts routine groundwater monitoring on a semi-annual basis. The purpose of
these activities is to evaluate the concentrations of VOCs in groundwater over time, and to measure the
effectiveness of the groundwater recovery and treatment system. Activities include collecting water-
level measurements in monitoring wells and the on-site interceptor trench sump and collecting
groundwater samples. Groundwater levels are measured in each monitoring well for the development of
groundwater elevation contour maps and to identify groundwater flow directions. Table H-l describes
the groundwater monitoring network. Figure 3 shows the groundwater monitoring well locations.
Groundwater concentrations are compared to MCLs (or a risk-based level if no MCL exists), which are
the performance standards identified in the 1996 ROD.
This FYR evaluates data from semi-annual sampling events conducted from 2018 through the first half
of 2022. Samples were collected from on-site and off-site wells (Figure 3). Of these samples, TCE,
cis-l,2-DCE, vinyl chloride and benzene were detected above their respective MCLs in seven on-site
monitoring wells in either the shallow alluvial aquifer or the intermediate zone of the bedrock aquifer
(Table H-2).3 Vinyl chloride, TCE and cis-l,2-DCE were detected above their respective MCLs in five
off-site monitoring wells in either the intermediate or deep zone of the bedrock aquifer (Table H-3).
Except for the June 2019 sampling event, VOCs had not been detected above MCL levels in CMW-85
(the most downgradient bedrock aquifer well) since December 1997 (Figure H-7).
Figures H-l through H-6 show time trends of groundwater monitoring data in wells CMW-5-2A, R-2,
CMW-5-11, the interceptor trench/sump, CMW-7 and CMW-12. General trends of groundwater
contamination during this review period have been fairly stable after a significant decrease during the
time the treatment plant has been operating. The pre-2022 cumulative VOC mass recovered since 1997
showed a continuous increasing trend, indicating that the groundwater remediation system continues to
remove VOCs from the various aquifers effectively. However, the curve is beginning to level off,
indicating that mass removal rates are slowing and becoming asymptotic (Figure H-8). Historically, the
system appears to have generally controlled the migration of contaminants off site and is retracting the
contaminant V OC plume. As part of this FYR, the EPA conducted a statistical evaluation of
groundwater time-concentration data. Figure H-l 3 includes the statistical analyses figures. This analysis
indicates contaminant concentrations in most wells that have a trend are expected to attain cleanup
within the next seven years with the exception of cis-l,2-DCE in R-2 and CMW-5-11A which are
estimated to meet cleanup goals in 2043 and 2037, respectively.
Routine groundwater monitoring also includes the analysis of monitored natural attenuation (MNA)
parameters. The Site's decision documents did not include MNA as a component of the selected remedy
for the Site. However, MNA parameters are collected to determine whether MNA may be occurring.
Sampling results from the first 2022 semi-annual monitoring event indicate that natural attenuation is
occurring. This finding is based on water quality results, including oxidation reduction potential, pH,
and chloride and methane levels, measured in on-site and off-site groundwater samples. Consistent with
previous sampling data, the presence of cis-l,2-DCE and vinyl chloride, with depth and horizontally in a
downgradient groundwater flow direction, indicates the presence of natural biodegradation processes in
the aquifers because these compounds are formed when TCE naturally biodegrades.
Source Area Assessment
Per a recommendation from the 2013 FYR Report and the 2018 FYR Report stating that a source of
contamination may still be present near well R-l, Cooper Industries performed a source area assessment
3 Benzene is not a site COC. The EPA will continue to monitor benzene to determine if it should be a site groundwater COC.
15
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in 2021. The objective was to delineate the extent of contaminant COCs in vadose-zone soils and
shallow groundwater in the area identified as a potential source. The assessment included 26 soil
samples from 13 soil borings (SB-1 through SB-13) and 14 groundwater samples collected from 1 -inch
diameter temporary assessment wells (TAWs) (TAW-1 through TAW-14), shown in Figure H-9.
TCE was detected in 23 of the 26 soil samples, at concentrations up to 69 milligrams per kilogram (mg/kg)
in sample SB-10 (26 feet to 28 feet). Cis-1,2-DCE was detected in six of the 25 soil samples, ranging in
concentration up to 0.1 mg/kg in sample SB-10 (26 feet to 28 feet). PCE was detected in one soil
sample, at a concentration of 0.023 mg/kg in sample SB-4 (26 feet to 28 feet).
Of the VOCs analyzed for the 14 groundwater samples, all VOCs but benzene were detected, as
summarized below:
• TCE was detected in all 14 groundwater samples, at concentrations ranging from 5.5 |ig/L
(TAW-3) to 7,900 |ig/L (TAW-10).
• Cis-1,2-DCE was detected in all 14 groundwater samples, at concentrations ranging from
6.7 (ig/L (TAW-4) to 85 |ig/L (TAW-10).
• Trans-1,2-DCE was detected in nine of the 14 groundwater samples, at concentrations ranging
from 0.51 |ig/L (TAW-6) to 4.1 |ig/L (TAW-5).
• 1,1-DCE was detected in eight of the 14 groundwater samples, at concentrations ranging from
0.47 (ig/L (TAW-14) to 4.5 |ig/L (TAW-9).
• PCE was detected in seven of the 14 groundwater samples, at concentrations ranging from
1.0 (ig/L (TAW-7) to 54 |ig/L (TAW-10).
• Vinyl chloride was detected in only one groundwater sample, at a concentration of
2.7 (ig/L (TAW-1).
The isoconcentration map for TCE in groundwater (Figure H-l 1) shows that the highest TCE
concentrations were detected in the vicinity of R-l. The EPA has reviewed the report and recommends
additional investigation of conditions in the unsaturated zone and groundwater beneath the building. The
EPA will review potential remedial actions in the future.
Vapor Intrusion Pathway Assessment
The 2013 FYR Report identified the potential for an unacceptable vapor intrusion risk on site and
recommended that the PRP investigate the vapor intrusion pathway. Cooper Industries performed a
vapor intrusion pathway assessment in 2021. The objective was to establish which COCs were present in
the indoor air and sub-slab vapor and their concentrations.
Figure H-l2 shows indoor air and sub-slab vapor sampling locations. Two COCs (PCE and cis-1,2-DCE)
were detected in indoor air samples collected in April and October 2021. PCE sample concentrations in
indoor air ranged from 1.56 |ig/m3 to 2.0 |ig/m3 and compared to the regional screening level (RSL)
(47 |ig/m3). Cis-1,2-DCE sample concentrations in indoor air ranged from 0.912 |ig/m3to 1.55 |ig/m3
(cis-1,2-DCE does not have an ambient air RSL).
Three COCs (TCE, PCE and cis-1,2-DCE) were detected in sub-slab vapor samples collected in April
and October 2021. TCE was detected in five of the six sub-slab vapor sampling locations, at
16
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concentrations ranging from 40.1 |ig/m3 (SS-3) to 6,270 |ig/m3 (SS-1).4 PCE was detected at five of the
six sub-slab vapor sampling locations, at concentrations ranging from 1.64 |ig/m3 (SS-4) to 16.9 |ig/m3
(SS-1). Cis-1,2-DCE was detected in two sub-slab samples, at concentrations ranging from 1.95 ug/m3
(SS-3) to 5.71 |ig/m3 (SS-6).
The results of the sub-slab soil gas and indoor air samples collected show that there is no current
unacceptable risk, and no further investigation/monitoring is needed at this time. While TCE was
detected at concentrations up to 6,270 |ig/m3 in sub-slab samples, TCE was not detected in indoor air
samples. These large differences can be explained by several factors precluding migration from below
the main building into the indoor air. The thickness of the concrete was measured at 10 inches.
Additionally, the concrete is in good condition and air movement in the main building is facilitated by
high ceilings and missing/broken windows throughout the structure. Four air sampling events were
performed inside the facility. No COCs were detected above RSLs in any of these sampling events. The
EPA agrees with these results and conclusions, with the caveat that, should site conditions change, then
vapor intrusion investigations/monitoring should be conducted.
Stack Air Emissions
The KDEP has not established air emission limits for the treatment system and does not require a permit.
The 1996 ROD required monitoring of stack air emissions to demonstrate compliance with performance
standards. The performance standards place limitations on discharge of TCE, cis-l,2-DCE and vinyl
chloride to the air. The point of compliance for the emission rate standard is the discharge end of the air
stripper exhaust stack. Air monitoring takes place on a quarterly basis in conjunction with the KPDES
discharge monitoring program. Table 7 summarizes stack air emissions results from 2018 to 2021, along
with the performance standards established in the 1996 ROD. As shown in Table 7, VOC air emission
levels were below emission performance standards during this review period, except for one exceedance
of vinyl chloride in May 2019.
4 The EPA's Vapor Intrusion Screening Level (VISL) calculator for commercial/industrial use models an indoor air
concentration of 188 ng/m3 from a soil vapor gas concentration of 6,270 ng/m3. This results in carcinogenic risk of 6 x 10"6
and a hazard quotient of 22, which is within the EPA's acceptable risk range for carcinogenic risk, but above the EPA's
hazard quotient threshold of 1. The EPA's VISL calculator is located at: https://www.epa.gov/vaporiiitriisioii/vapor-iiitriisioii-
screeniiig-level-calculator
17
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Table 7: Summary of Stack Air Emissions, 2018 to 2021
Air Strippe
r Exhaust Gas Analvtieal Results (pphv)"
Date
Cis-1,2-DCE
TCE
Vinvl Chloride
Allowable Emission Rate (ppl>v)b
5,850,000
19,600
837
1/26/2018
0.347
11.8
4.83
4/17/2018
89.0
26.2
7.85
7/9/2018
111.4
15.4
5.89
12/5/2018
666
278
139
2/14/2019
12.7
1.17
1.89
5/7/2019
3,838
1,160
2,210
9/9/2019
49.8
1.30
1.47
12/4/2019
323.0
5.90
27.2
2/3/2020
233
13.5
13.4
4/22/2020
65
3.6
4.3
9/3/2020
440
3.2
82
12/8/2020
1.220
98.9
124
3/3/2021
2,100
240
240
5/25/2021
2,200
1,700
510
Notes:
a. The source is Table C-1 in the 2022 First Semi-Annual Monitoring Report (PDF page 96).
b. The source is Table 9.2 in the 1996 ROD (PDF page 58).
ppbv = parts per billion by volume
Bold value = VOC air emission level is above the emission performance standard.
The treatment system operation was not in operation from January 2022 through June 2022 due to a pump failure.
Therefore, no air emissions samples were collected during this time.
18
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Disclaimer This map and any boundary lines within the map are approximate and
subject to change The map is not a survey The map is for informational purposes
only regarding the EPA's response actions at the Site. Map image is the intellectual
property of Esri and is used herein under license Copyright © 2020 Esri and its
licensors. All rights reserved. Sources: Esri, Esri Community Maps Contributors,
VGIN, © OpenStreetMap, Microsoft, Esri, HERE, Garmin, SafeGraph.
GeoTechnologies, Inc, METI/NASA, USGS, EPA, NPS, US Census Bureau, USDA,
Maxar. Microsoft, the EPA's, Office of Mission Support; Data Steward: the EPA's,
Office of Land and Emergency Management - NPL Superfund Site Boundaries (EPA
Public 2022) and the 2022 First-Semi Annual Monitoring Report.
National Electric Coil Co./Cooper
Industries Superfund Site
Community of Dayhoit, Harlan County, Kentucky
I 1 1 1 1 1
0 100 200 300 400 500 Feet
Last Modified: 2/21/2023
Figure 3: Detailed Site Mai
CMW-85
CMW-5-11B
CMW-5-11A
CMW-5-2
CMW-5-2A
CMW-9
CMW-7
CMW-12A
CMW-12-16
~I Approximate Site Boundary
^ Shallow Alluvial Aquifer Well
Intermediate Bedrock Aquifer
Recovery Well
® Intermediate Aquifer Well
Deep Bedrock Aquifer
Recovery Well
4 Deep Bedrock Aquifer Well
- Interceptor Trench
CMW-13A
CMW-13
19
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Site Inspection
The site inspection took place on 1 1/16/2022. Participants included Craig VanTrees (EPA RPM),
Adam Friedman (EPA human health risk assessor). Bill O'Steen (EPA hydrogeologist),
L"Tonya Spencer (EPA community involvement coordinator), Christoph Uhlenbruch and Larry Tackett
(KDEP), Jeffrey Schick (Quantum Management Group, Inc. for Cooper Industries), Mike Morris (Shield
Environmental Associates), and Kirby Webster and Lauren Johnson (EPA contractor Skeo). The
purpose of the inspection was to assess the protectiveness of the remedy. Appendix I includes the site
inspection checklist. Appendix J includes the site inspection photos.
The Site was accessed through the front access gate off Day Hoit Drive. While many salvage vehicles
were present on site, they are not stacked on top of each other and parking and walking within the
fenced area was easy to navigate.5 Participants looked inside the main building and observed the
locations of former process activities, as well as the locations where sub-slab samples were collected.
The concrete floor of the main building is in good condition. No cracks or other evidence of disrepair
was observed. The floor is about 10 inches thick, as observed at the edge of the loading dock, as well as
by the PRP contractor when the sub-slab samples were taken. The main building is large and houses a
lot of salvage parts, but it is relatively easy to walk around. The building is in disrepair (though still
standing). Parts of the roof are leaking, and some ponding was observed on the floor (the day prior to the
site visit had been rainy). Windows are missing and pigeons seem to frequent the building (a few
pigeons were observed, and droppings were prevalent). The building is well ventilated due to the height
of the ceilings and missing windows. There does not appear to be a continuous presence of workers in
the building. A friend of the owner was using part of the warehouse to fix his personal vehicle.
Site inspection participants observed the air stripper building, which has been enclosed to reduce noise
for nearby neighbors. The treatment compound building is in good condition and no issues were noted.
Site inspection participants viewed all monitoring wells and then the trench system. All wells were
labeled and locked. Some labels were beginning to fade. The wells were all accessible. The top of well
CMW-7, located in a residential yard, has been damaged. It may need to be repaired.
The Site's entire Administrative Record is available online on the EPA's site profile page:
http://www.epa.gov/superflind/national-electric-coil-cooper~industries.
V. TECHNICAL ASSESSMENT
QUESTION A: Is the remedy functioning as intended by the decision documents9
Question A Summary:
Yes, the remedy is functioning as intended by site decision documents. During the 1991 removal action,
contaminated soils were excavated and removed from the Site and replaced with clean fill. Residents are
connected to the public water supply and no one is currently using the groundwater at the Site.
Additionally, institutional controls are being put in place to prevent future groundwater use. Ongoing
source investigations underneath the building have identified more soil contamination. Given that there
is not a completed exposure pathway because of the building foundation, this is not a current
protectiveness issue. However, more investigations and discussions about potential remedial
investigations may result in the need for soil institutional controls.
5 The 2018 FYR Report stated that, during the site inspection, the automobiles present made it difficult to navigate the Site.
20
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The long-term monitoring data indicates a generalized decrease of VOC contamination in both aquifers
over time. Statistical analyses indicate contaminant concentrations in most wells that have a trend are
expected to attain cleanup goals within the next seven years with the exception of cis-l,2-DCE in R-2
and CMW-5-11A which are estimated to meet cleanup goals in 2043 and 2037, respectively. However,
mass removal rates are slowing. Additionally, concentrations of several COCs remain above MCLs and
appear to be persistent at a few wells, indicating that contaminant mass sourcing to groundwater
remains. Data indicates that the groundwater pump-and-treat system appears to generally control the
migration of contaminants off site. Prior to June 2019, VOCs had not been detected above MCL levels
in off-site downgradient well CMW-85. In June 2019, TCE was detected at a concentration of 10.5 |ig/L
(MCL = 5 |ig/L). TCE has been below detection limits during the August 2019, June 2021 and
June 2022 sampling events (Figure H-7). In 2021, the PRP performed a source area assessment to
delineate the extent of contaminant COCs in soils and shallow groundwater in an area identified as a
potential source. This assessment found elevated concentrations of TCE in soil (up to 69 mg/kg) and
groundwater (up to 6,920 ug/L) in the vicinity of well R-l. The EPA is reviewing these results and will
work with the PRP to determine if the groundwater extraction and treatment system and/or remedy
needs to be optimized.
O&M activities are ongoing and conducted in accordance with the Site's 2012 amended O&M Plan.
During the first six months of 2022, the groundwater recovery system was not operational due to a pump
failure. The rebuilt pump was received and reinstalled in July 2022, and the system has been operating
as designed since then. Monitoring of the discharged groundwater has continued during the operation of
the remedy to demonstrate continued compliance with KPDES requirements. According to the 2022
First Semi-Annual Monitoring Report, the current effluent limitations have been achieved throughout
the reporting period.
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time
of the remedy selection still valid9
Question 6 Summary:
Exposure assumptions, cleanup levels and RAOs used at the time of the remedy selection remain valid.
The 1996 ROD established groundwater cleanup goals for site COCs based on federal MCLs (except for
1,1,2,2-tetrachloroethane) and identified Safe Drinking Water Act MCLs as ARARs. ARARs have not
changed for any of the COCs since the Site's 1996 ROD (Table K-l). The cleanup goal for 1,1,2,2-
tetrachloroethane was based on the practical quantitation limit, which equals a risk level of 6 x 10"5 for a
lifetime residential scenario (at the time of the 1996 ROD). To evaluate if the groundwater cleanup goal
for 1,1,2,2-tetrachloroethane remains valid, a screening-level risk evaluation was conducted (Table L-l).
The groundwater cleanup goal for 1,1,2,2-tetrachloroethane is equivalent to the EPA's upper bound of
the cancer risk management range (1 x 10"4) and results in an HQ below the EPA's threshold of
1.0. 1,1,2,2-Tetrachloroethane has only been detected once at the Site, in July 1993 at 2 |ig/L at MW-17.
Table L-l shows that this detection of 1,1,2,2-tetrachloroethane is equivalent to risks within the EPA's
cancer risk management range and results in an HQ below the EPA's threshold of 1.0.
The 1996 ROD established performance standards to place limitations on the discharge of TCE, vinyl
chloride and cis-l,2-DCE into the air from the treatment system. The performance standards were based
on risk-based levels, except for cis-l,2-DCE because an inhalation unit risk (IUR) factor has not been
derived. The emission rate for cis-l,2-DCE was based on 401 KAR 63:022 which was repealed in 2021
and therefore could not be compared to current standards. However, it should be noted that 2018-2021
emissions of cis-l,2-DCE are well below the 1996 ROD performance standards (see Table 7). To
evaluate if the performance standards for TCE and vinyl chloride remain valid, this FYR conducted a
21
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screening-level risk review (Appendix L). The screening-level risk review found that the current RJRs
are more stringent for TCE and less stringent for vinyl chloride than those used to calculate emission
rates in the 1996 ROD (Table L-2). The current IUR for TCE is more stringent than that used in the
1996 ROD by a factor of 2.4. The highest emission rate recorded for TCE during this FYR period was
1,700 parts per billion by volume (ppbv) (May 2021) which is lower than the allowable emissions rate
(19,600 ppbv) by a factor of 11.5. Therefore, the change in the IUR toxicity value for TCE is not
currently a concern. The stack emission standard for TCE should be evaluated to determine if a change
is needed.
The Conceptual Site Model in the BRA was reviewed to ensure that all potential exposure pathways had
been evaluated and considered in the development of the 1996 ROD. Although inhalation of VOCs was
evaluated as part of a residential showering scenario (via soil gas) it was not considered for the Site
despite the presence of VOCs in groundwater at elevated concentrations. In 2021, the PRP performed a
vapor intrusion pathway assessment in the on-site building. The results showed that there is no current
unacceptable risk and no further investigation/monitoring is needed at this time. While TCE was
detected at concentrations up to 6,270 |ig/m3 in sub-slab samples, TCE was not detected in indoor air
samples. These large differences can be explained by several factors precluding migration from below
the main building into the indoor air. The thickness of the concrete was measured at 10 inches.
Additionally, the concrete is in good condition and air movement in the main building is facilitated by
high ceilings and missing/broken windows throughout the structure. Four air sampling events were
performed inside the facility. No COCs were detected above RSLs. The EPA agrees with these results
and conclusions, with the caveat that should site conditions change, then vapor intrusion
investigations/monitoring should be conducted.
Due to the presence of VOCs, this FYR Report evaluated the vapor intrusion exposure pathway for off-
site wells with COC exceedances of cleanup goals within 100 feet of enclosed buildings (CMW-7 and
CMW-85, see Figure 3). Table L-3 shows that the estimated vapor intrusion risk for residential
exposures using the maximum concentration detected during this review period slightly exceeds the
EPA's acceptable risk range in well CMW-7 (2 x 10"4) and are above the target noncancer HQ of 1.0 in
well CMW-85 (2.0). This evaluation is a conservative assessment as there is shallow groundwater
overlaying the deep groundwater. Shallow groundwater is thought to not be impacted southwest of the
site (where these two wells are located) due to the direction of groundwater flow.
The RAOs identified in the 201 1 ESD were to: (1) control risks posed by direct contact with
groundwater; and (2) minimize migration of contaminants in groundwater. Residents are connected to
the public water supply and no one is currently using the groundwater at the Site. Additionally,
institutional controls are being put in place to prevent future groundwater use. Historically, the
groundwater recovery system appears to generally control the migration of contaminants off site and is
shrinking the VOC plume. The water quality data also show that natural attenuation is occurring within
the plume. The 1996 ROD said that the selected remedy will operate for an estimated period of 30 years,
during which time the system's performance will be carefully monitoring on a regular basis and adjusted
as warranted by the performance data collected during operation.
QUESTION C : Has any other information come to light that could call into question the protectiveness
of the remedy9
No other information has come to light that could call into question the protectiveness of the remedy.
22
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VI. ISSUES/RECOMMENDATIONS
Issues/Recommendations
OU(s) without Issues/Recommendations Identified in the FYR:
None
Issues and Recommendations Identified in the FYR:
OU(s):
Issue Category: Institutional Controls
OU-1
Issue: Institutional controls are not in place for groundwater on some properties
where contamination exists and has migrated.
Recommendation: Complete restrictive covenants on all properties with COC
concentrations above safe drinking water standards.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA/State
9/20/2025
OU(s):
Issue Category: Other
OU-1
Issue: The estimated vapor intrusion risk (based on the VISL model and default
parameters) for residential exposures off site slightly exceeds the EPA's
acceptable risk range in well CMW-7 (2 x 10~4) and is above the target noncancer
HQ of 1.0 in well CMW-85 (2.0).
Recommendation: Further evaluate the residential vapor intrusion pathway off
site to ensure there are no completed exposure pathways to contamination.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA/State
9/20/2025
OU(s):
Issue Category: Other
OU-1
Issue: Soil vapor samples underneath the building have identified elevated levels
of VOCs (2022 Vapor Intrusion Pathway Assessment Report).
Recommendation: Evaluate conditions in the unsaturated zone and groundwater
underneath the building. Evaluate appropriate response actions, including
evaluating the need for additional institutional controls.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA/State
9/20/2025
23
-------
OU(s):
Issue Category: Other
OU-1
Issue: The 2021 source area assessment confirmed that there is a source of
contamination present near well R-l.
Recommendation: Develop and evaluate options to mitigate elevated VOCs in
soil and groundwater near well R-l.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA/State
9/20/2025
OTHFR FINDINGS
Several additional recommendations were identified during the FYR. These recommendations do not
affect current and/or future protectiveness.
• Benzene has been detected in groundwater samples at concentrations above the 5 |ig/L primary
drinking water standard. The EPA will continue to monitor benzene to determine if it should be a
site groundwater COC.
• If site conditions change in the future, additional vapor intrusion investigations/monitoring need
to be considered.
• Prior to June 2019, VOCs had not been detected above MCL levels in off-site downgradient well
CMW-85. In June 2019, TCE was detected at a concentration of 10.5 |ig/L (MCL = 5 |ig/L).
Continue to monitor CMW-85.
• The current IlJRs for TCE are more stringent than those used to calculate acceptable emission
rates in the 1996 ROD. Evaluate if the stack emission standard for TCE needs to be updated.
• The air emissions standards presented in the FYR are based on levels from the 1996 ROD, which
stated that these were intended to be temporary health-based standards based on air dispersion
modeling done with one year of site-specific atmospheric data, adding that "five years of site-
specific atmospheric data shall be collected in order to derive a final dispersion factor." Since
these standards were intended to be temporary, and because the IIJR for TCE has become more
stringent, meteorological data should be collected, and dispersion modeling performed, in order
to ensure the emissions performance standards still result in an ambient air concentration that is
protective of human health.
• Section 9.2.3 of the 1996 ROD says that "ambient air monitoring shall also be performed at the
Holiday Trailer Park located next to the Site facility. The fence line separating the Site from the
Holiday Trailer Park property shall serve as the point of compliance." Ambient air monitoring
should be implemented to be performed at the Holiday Trailer Park property to ensure ambient
air concentrations do not pose a potential risk to human health. Alternatively, air dispersion
modeling can be performed to demonstrate that ambient air concentrations resulting from the
maximum detected emissions would not pose a risk to human health.
• The emission rate for cis-l,2-DCE was based on 401 KAR 63:022, which was repealed in 2021.
Since there is no IIJR for cis-l,2-DCE, a surrogate inhalation toxicity value should be identified
before the next FYR to determine a health-protective air emission standard. This value can be
identified through consultation with the Superfund Technical Support Center.
24
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VII. PROTECTIVENESS STATEMENT
Silowido IVoUtUmmicss Slitlemciil
Protectiveness Determination:
Short-term Protective
Protectiveness Statement:
The remedy is considered protective in the short term because the remedy currently protects human
health and the environment. Exposure pathways for both soil and groundwater are being controlled,
nearby residences have been connected to the municipal water system and groundwater is being
monitored. For the remedy to be protective over the long term, the follow ing actions should be taken:
complete restrictive covenants on all properties affected by groundwater contamination; further
evaluate the residential vapor intrusion pathw ay off site to ensure there are no completed exposure
pathways to contamination; perform additional investigation of conditions in the unsaturated zone and
groundwater near well R-l and evaluate options to mitigate source material; and develop and evaluate
appropriate response to elevated VOCs in soil and groundwater near well R-l.
VIII. NEXT REVIEW
The next FYR Report for the National Electric Coil Co /Cooper Industries Superfund site is required
five years from the completion date of this review.
25
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APPENDIX A - REFERENCE LIST
2022 First Semi-Annual Monitoring Report. National Electric Coil Superfund Site. Harlan County,
Kentucky. Prepared for Cooper Industries, LLC by Shield Environmental Associates, Inc.
August 2022.
Addendum to the Fourth Five-Year Review Report for National Electric Coil Superfund Site. Dayhoit,
Harlan County, Kentucky. U.S. Environmental Protection Agency Region 4. September 2021.
Explanation of Significant Differences. National Electric Coil/Cooper Industries Superfund Site.
Environmental Protection Agency. July 26, 1997.
Explanation of Significant Differences. National Electric Coil/Cooper Industries Superfund Site.
Environmental Protection Agency. February 8, 201 1.
Fourth Five-Year Review Report for National Electric Coil Superfund Site. Dayhoit, Harlan County,
Kentucky. U.S. Environmental Protection Agency Region 4. September 2018.
Operation and Maintenance Plan. National Electric Coil Site. Harlan County, Kentucky. Prepared by
Law Engineering and Environmental Services, Inc. July 1998. Revised by Shield Environmental, Inc.
August 2012.
Record of Decision. National Electric Coil Co./Cooper Industries. U.S. Environmental Protection
Agency Region IV. September 30, 1992.
Record of Decision. National Electric Coil Co./Cooper Industries. U.S. Environmental Protection
Agency Region IV. April 26, 1996.
Second Five-Year Review Report for National Electric Coil Superfund Site. Dayhoit, Harlan County,
Kentucky. U.S. Environmental Protection Agency Region 4. September 2008.
Source Area Assessment Report. National Electric Coil Superfund Site. Dayhoit, Harland County,
Kentucky. Prepared for Cooper Industries, LLC by Shield Environmental Associates, Inc. April 2022.
Third Five-Year Review Report for National Electric Coil Superfund Site. Dayhoit, Harlan County,
Kentucky. U.S. Environmental Protection Agency Region 4. September 2013.
Vapor Intrusion Pathway Assessment Report. National Electric Coil Superfund Site. Dayhoit, Harland
County, Kentucky. Prepared for Cooper Industries, LLC by Shield Environmental Associates, Inc.
August 2022.
A-l
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APPENDIX B - CURRENT SITE STATUS
K11 v i roil in en 1211 I ml iesi 1 ors
- Current human exposures at the Site are under control.
- Current groundwater migration is under control.
Arc Necessary Inslitnlion;il Controls in Place
[HaFx Some O None
Ihis (lie KPA Designated (lie Silo sis Silcwklc Ready lor Anticipated I so?
I I Yes No
I his (lie Silo Keen Put into Uense.
No
B-l
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APPENDIX C - SITE CHRONOLOGY
Table C-l: Site Chronology
Li csrs
Date
The KDEP discovered VOCs in 12 residential wells near the Site
February 27, 1989
The EPA initiated a removal action
Clean water supplies provided to residents impacted by the Site
March 4, 1989
The EPA completed the removal action
March 21. 1989
The PRP started interim response actions, including provision of
emergency water supplv tanks
April 1, 1989
The PRP started interim response actions: connecting residents to the
Black Mountain Water District municipal water system, flushing and
cleaning out site sewers and drains, decontaminating floors, and
excavating 200 cubic yards of impacted soils and taking them off site
for disposal
August 7, 1989
The KDEP began a preliminary site assessment
September 11. 1989
The KDEP completed the preliminary site assessment
September 20, 1989
The EPA began a site inspection
January 11, 1990
The EPA completed the site inspection
June 20, 1990
The EPA issued a UAO to the PRPs requiring immediate actions to
mitigate releases of hazardous substances
October 11. 1990
The PRPs submitted a Removal Action Report to the EPA
March 11. 1991
The PRPs completed the removal action, removing 5,100 tons of
contaminated soils and disposing of them off site
March 31, 1991
The EPA proposed the Site for listing on the NPL
Julv 29, 1991
The EPA approved a removal action
October 31, 1991
The EPA executed an Administrative Order on Consent for performance
of RI/FS work
The PRPs began the RI/FS
May 18, 1992
The EPA issued an Interim ROD to initiate groundwater cleanup
September 30, 1992
Site's listing on the NPL was finali/cd
October 14, 1992
The EPA approved a work plan to allow air stripper startup on an
interim basis
December 1, 1992
The EPA issued a U AO to the PRPs to perform the Site's interim
remedial design/interim remedial action in accordance with the Site's
1992 ROD concurrent with the RI/FS
December 23. 1992
The PRPs began the interim remedial design
January 8, 1993
The PRPs completed the interim remedial design
February 25, 1993
The PRPs began construction of the interim response action to recover
and treat groundwater contamination during completion of the RI/FS and
final ROD
April 1. 1993
The PRPs completed construction of the interim action groundwater
rccovcrv and treatment svstem
July 30, 1993
The EPA completed the Site's ecological risk assessment
November 30. 1994
The PRPs finali/cd the RI/FS
EPA issued the ROD for groundwater cleanup
April 26, 1996
The EPA issued a U AO to the PRPs to complete the remedial
design/remedial action for the final groundwater rcmcdv
May 20, 1996
The PRP began the remedial design
June 4, 1996
The EPA signed an ESD to include a change to the groundwater rcmcdv
of the shallow aquifer
July 26, 1997
The EPA approved the Site's remedial design
September 29, 1997
The EPA completed the Site's Preliminary Close-Out Report
August 23. 1998
The KDEP requested a Response Action Plan from Cooper Industries to
address PCBs in soil on mobile home park property
July 1, 2001
C-l
-------
Li csrs
Date
The EPA submitted a letter to the KDEP stating that the PCB levels
detected in the four mobile home park soil samples do not present an
unacceptable risk and response action is not warranted
September 1, 2001
The PRPs removed 170 tons of PCB-impacted soil from the mobile home
park property and disposed of it off site, based on a request from the state
October 1, 2001
The KDEP issued a "no further action" letter to the PRPs for
PCB removal
November 5, 2001
The EPA issued the Site's second Administrative Order on Consent
January 31, 2003
The EPA issued the Site's first FYR Report
September 30, 2003
The EPA issued the Site's second FYR Report
September 30, 2008
The EPA issued the Site's second ESD
Fcbruarv 8, 2011
The EPA issued the Site's third FYR Report
September 30, 2013
The EPA issued the Site's fourth FYR Report
September 20, 2018
The EPA signed the Addendum to the Site's fourth FYR Report
September 8, 2021
The PRP submitted the Source Area Assessment Report to the EPA
April 27, 2022
The PRP submitted the revised Vapor Intrusion Assessment Report to
the EPA
August 22, 2022
C-2
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APPENDIX D - 1989-1991 RESPONSE ACTIONS
Beginning in March 1989, residences affected by contaminated groundwater received bottled water
and water from temporary aboveground storage tanks. In August 1989, PRP Cooper Industries
connected residential groundwater users in areas either already affected or at risk of future
contamination to the public water supply system. The PRP conducted additional interim response
actions in June 1990, including:
• Flushing and cleaning out sewers and drains.
• Removing about 200 cubic yards of soil from Outfall 001, Catch Basin D-5, the loading dock
area and a former burning area.
The cleanup level used to determine the soil removal limits during this on-site removal action was
25 mg/kg PCBs. About 400 tons of soil was removed and taken off site for disposal. In 1991, PRP
Cooper Industries excavated and removed the clay drain lines and manholes leading to Outfall 001 and
replaced them. The loading dock gasket was also removed, the degreaser tank pit was cleaned, and all
plant floor, loading dock and degreaser pit drains were plugged.
In October 1990, the EPA issued a Unilateral Administrative Order (UAO) to the PRPs to conduct an
interim action to remove contaminated soils on site and address an immediate threat to human health.
PRP Cooper Industries undertook the removal action activities. The EPA supervised the removal action,
which took place from October 1990 to October 1991. About 5,100 tons of soil were excavated and sent
for off-site disposal. Table D-l lists the EPA action levels that informed the on-site removal. All
identified site soils (surface and subsurface) exceeding EPA action levels were excavated and excavated
areas were backfilled with clean soil. Soil removal activities took place in five principal areas, shown
in Figure D-1.
Table D-l: EPA Action Levels - 1991 Removal Action
Contaminant
EPA Action Level"
PCBs
10 mg/kg
Total VOCs
10 mg/kg
Lead
5 mg/L TCLP
Chromium
5 mg/L TCLP
Total lead and chromium
100 mg/kg
Notes:
a. The source is the Site's 1996 ROD (PDF page 18).
mg/L = milligrams per liter
TCLP = toxicity characteristic leaching procedure
D-l
-------
Last Modified: 2/21/2023
Riverbank Fill
Equipment
and Drum Storage
Area
("MMKsBQZSlMl
D-5
Catch
National Electric Coil Co./Cooper
Industries Superfund Site
Community of Dayhoit, Harlan County, Kentucky
Disclaimer This map and any boundary lines within the map are approximate and
subject to change. The map is not a survey. The map is for informational purposes
only regarding EPA's response actions at the Site. Map image is the intellectual
property of Esri and is used herein under license Copyright © 2020 Esri and its
licensors All rights reserved. Sources: Esri, Esri Community Maps Contributors,
VGIN, © OpenStreetMap, Microsoft, Esri. HERE, Garmin, SafeGraph,
GeoTechnologies. Inc, METI/NASA. USGS, EPA. NPS, US Census Bureau.
USDA, Maxar. Microsoft, the EPA's, Office of Mission Support, Data Steward the
EPA's. Office of Land and Emergency Management - NPL Superfund Site
Boundaries (EPA Public 2022) and the 2018 Five-Year Review Report
Figure D-l: Removal Action Soil Excavation Boundaries
D-2
-------
APPENDIX E - RESTRICTIVE COVENANTS
Figure E-l: Environmental Covenant (May 2, 2018)
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roticci of isralffisfit ctaffniin. sty^l toes WtfU tor
Director, Suparfuml IMfen
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Regan 4
t bM Elufiedj CL* tm Eiwlranmartar Camnant doaa
w* In any way i «»t? «•<> ov rr A .n It* r -pe-t» *hi>:f< is *..j(*ct «o t»
Ennjanrntriiii Covenant fultiemtMB Itw Act ul jwuvtm ihti. i ••»iioi*nanl«l Covenant
fc#8Rdlfi 8fN w.iv £*ti j> FPA r- fcuc- Property
H. 5«iiS"j8Ltl * •nf 11 in to
yn#r'o'C»*6» !" mn\ respen, -m< vallci'lj lagalrtj- antl if ttw 'twwrg
piwltte'^ J i ¦ ¦« m «• / i Li- iittfck'd j> Urtuo ic-i
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E-6
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pmom Dffwster; Sup§*fcid OWw* EPA Region 4 Ml Doctor, KsHfcjsky DMim of
Wiwiitt IImi Hekv* ^ «*»r» r ,it> •• wrwii Co^wt *?*"*« pm« wte it -in
post^wrt o* T® Ff< pri; ®i|~h jy» \ fTT ^Tfch ** "*r'ccr In tfrw
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E-7
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n TESTIMONY 'WHEREOF, the
- L.-I
utlU& dVl Cft!»WrfV.
(Grtrrtor/G ran tw)
fstmii
Date _
—' I i—
"Tit tomgolty CrrvironmenSal Cavern ®w j«
William*, Jr. and Angatla WRIUrrw on tf® tt» -j 'V aay of j
1
Notary Pu-b^iii
My Commtoatarv ixpffnii:
f
'.V« M'J,
E-8
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Cooper Irtdualrfoti LLC iGnanto*}
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fcpifiQl^ G§¥®#iiiFtf UdHkktt fiw by
i 8 Cfafy #Jtiv *T'*wi *Oj;v«&IHTt®'V»ai r! t OCfW I h"*li*t*!'98i, Lie. on fill
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J. «S
KENTUCKY ENBtOY *W
nv«i -",wr*w*l Co*r« i c 1
fcn^lisfwwni Cifeti
Dirwaor. Dlfttftft
Managommt
COMMONWEAtTH Of KENTUCKY
Hl§ torvgoing Eftvifw*'** ~:.t , cx^ra
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liMTSD STATES ENVIIWWKMTAL PROTBOTWN AWNCV
Th« bmm,. mbsik* ww»» wwiw »v
But « nm iw'wi
,2011
III >tnt vrfw l-i,fynnpiu Pn»v^ia« .\acrw
eupufundDteMon
STATE OF GEQROA I
>
COUNTY OF OEKALB )
I" ?Arnm>«l(i t ..WPtanf «M nckra*'ftao«i Ce'om m« b/ FrtnkKr.
6. Hill, J! Kitut. Sup* W n.<„itvi UnlMwt Stale* Kmrlron mental frotectiun Agency,
•i It eh\ a> AakMLr 2018
AUQINt 18, 8010
Thtoh»l%rtert bv
it —¦ 1- A 11 —
>• ^ irwejn
Att~> Qiu:« R G'fc-I* Cvj
11901 WiUhire B3i.iev«ii
Sun* 1400
CASanS^OSGS
Tataphom: {310} 442.8834
Facsimile plf- fTO «•=>{•
E-10
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W GlNNINli at »<-n i"tv, t.)*•» imti ¦'" f "I U ,'j H a^miy »iu lit, wMeh In* (*»
wars 8 3• 45 W 1! ~*i km * j,.-**- f.«le t«w «i*> fh« Hgti* o* mi, Irw t,f „> 5,
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8 >1 i * 'f* "t "1%^ 1 Htpr »%At prcjpMy northwif-
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FIGURE 3
01 isii oxen wMiuiMj t
E-12
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CLERK Of COURT
hmmjuicmmm
* <^X. , of •*» htoftan County
Co in drs [hit r+k* tm^pq rpvenan* ard Cttroeicartficn contest*
W JS U\!0fili M ^ly Of*'* i* 'i-r 3 M >*3 that * ft" ?vsff< * I? iflt tfs^f
*< ^ - — »«® *OV- *«* «fc TOpjS#?
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4* IT
itr" v< •»< »"* i
E-13
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Figure E-2: Amended Environmental Covenant, September 27, 2017
DOCUMENT TITLE
E-14
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AMKNtWD fCNYfRONMEKT .41, COVENANT
H» tfeMBMHWaNk «f >» '' ^ <.«!> <•».»•>» 1 feT""'
O-.M,,!,' '>• .>1 ' : ¦> if •. H < ' .[!•' ' 'J M'N hlj't 1 s I 1 l[-
l ,i > » • ¦ HI «* K *t n »> , < . y,. loclmliies, LLC
"1 loMenf at' "QrattMaT).
WHEREAS, • ni< I. «>*• • i« ' 1 "» •' >'« W5 Dayhnfc Drive
(K¥ J1S2), Keith, Htrtm County, Rcmucky, f.< "¦ ¦> ill. - ti., r, 11., ,v. ,, iV , Am
CiimiiiIJ' MabUnmce FwlHtf, RYTC# SI 3," mm p-i<» »• > v.iiw.l .• 1
lf>3it»ril* H».l. - • i."> !')'• » i. Mi..
H „ I,' ¦ [>.. ill ( , s , I) 't ' I'.; ,1 Ml tt ; MC .-! «iM»( U.S.
' F, * (:li*«ltill9 Of
Biiterliiwl. Riwr,«hew* Noiftallltrli Bill with
>,i J«> . . < • M*nMiNr,tmi> N.i'i." .ii> i.'-' l.;( l ,
wiilif of Cwriberitml River, ¦ taw kr theme » 5#* *»', a
dtaanee of 1«& «M to • tonefi thence W 41'
1 ">¦ i! ',1 II.. v. - , 1 ' - U. Hi |>. ai-i> > t ji
The above dtmtiheic pared! ewilttiiif 16 : ~ . * •' • |f»C | afirtww/
• \ j.il'l \ . 'I ' ii '•>. . • - i I " mi i ' «'i Co*i I'M •• t "i ;m) m ' ..mill
M.Bl-itt) !e IMS 2J4,tlJ-2ift,
WHEREAS, tttiior it the fin E*viwwn«tai
Covemust dated Auauat 24., «)lt\ if» tine Official focnnfa Marin* CiWfit}* Owk'»
. I»,u. I, tm Til (the "CMfiwiil BmmmmmM Gmmmar*
WHIiltEAi, i tarty pnspeitf J • .. ,1. v • f «•» I •• ¦»••• ' '
. \ , i I * . ¦ I,*, r, >' • i. •.(> „ > • - 1 » i-
Pr««i«» Aggmf t f'EI1*"! R«oe > i . > > i •' *1 •> •I ,4«>0 i
, ' ...I,, .,,1 '• ! , , I. .. Si l, 'II , I. « Mm l» ' , b.
-wxr letukia. mmim ms
pmumita KRS J24.1 -.«itll'iKfiiiMie-ii»«-|fi*r»lsC5tt.i.*»aiiEB' i:
WHEREAS, IWK, U»
Propeny was 'i* nAjoci af mfcraoncanl wiuwliiil action pmmmt 'to KHS i24.(**l
Chc«l;ll«iw Ow -mm Suptrtima ielioirK
WHEREAS, 11 i ' ' »ii. i i ,i i i
nab#®* .1. ii i> >t li'I » i, , - . h ii' ¦>. -i.t ... un h1 '"H
Mk s|Ksifie«lf« il l . . , . l t .1 li. i i. r» k 1 •« < ''•>•• ,h-r !•»• »U»
"bnpactni *»¦*! mum piiilltwiafl)' 4mwM » islta*;
i
E-15
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H.T < W >< 1 In.n Pin ln>. . ri f itx c.inn
puceJitm r- w "*>~(, .« II. *«.¦!<"MM
tliv I..K » ».) t»>\\ ,n.ll in' 'A IMU,- ih-v. >
.»« B, iif.Sf feet to a point, fence K 43« 0T 44* B, Olitt fat to li* tnie Poin*
OfBegiBlillf ciflXrd Ke-tii^i n w.r'^' -«^r I i '«¦ Ut
Jf 16"Il, 34.00 i t. I, a p. II. V.' itMl fW 41" V.
a f,wt iK" a \ ">• 5!" 5*. % M.m I. i Kit I l.< the »«•„ !',««
H I'UKi.n,- ii mtHf 1,700 >.|. ( i •• 1 |v( I l> >Vj.
WHEREAS. Ilh I iJlT ll Cl kl I * I .»• ,* lill.lillrsij U,' ¦» . I,">'ik'l»
nl.,i.,n.\ II .fii. m,I.r»' •m'l.Ji | r, i I'm1'". 1M> ->-t tih «i „,<>>. i 'inr •*
ii.i.lik'iii . >. i * mil vinyl chloride) I a- »> ui i • iil.li. I i » as*
k 1 m ¦. t -fvi >11111*1 ii i!» >i-* t>i. 'i- • i f'f.fij;
WHEREAS, Qtmm Mi Cooper turn fiopmi, nqpeciivdy, ¦ Ct rm I,.. I' mi ,t.
(he Mt, st.^-ttuiK- .i . !> ii.' . m,.i u,... i if >M!.i i. ii, >t' a«'r.-.n.iM
call ivIV " rIntr.l - i ?i,:LA*»fcinkJ«l,... "v HVJ-, -te . I
..oil",., , ,'.r- ,v , r.l 'i. rii-l. I* I - Am V.i.Ii >t,»" »< • .« IM'iny
ei|>v ,ii.i i . iIk i i< w i > -'.it • i 1 i' -'Ji-it- ,fH> • ivt'ui ,ii of
„ M •<« V'-. - ** -1-ul- \irfifeeittineProperty;
WHEREAS, "Mi o'mi.K. ! ¦ n u -n -n '*11# i< . .«¦!(! ,v i.ii-u.i
ll>,*,» KlNM. ll„>. • I I i'HJVl »> *ii! IV "1 I'll .1.1 ill. I' .<¦«-,»«. >.,,.1 11 «T lull-1»1 IIU'
. il. * >iw I.itt.1 III'. >. i„lv> I.'I ..I ii- !•. ,vf' ' > • kh!> II'* •..» I>« wi.,.v
¦illw imptetlPitMlesQf the .Wsis^
Willi 'V •' !>(• -II. tv Is. UMtK
I.u.n.i, h; , > 11-1):!. mi I tS i' i,. ii i • "i> -lis. MI® oft the Propem . h.ju .
•U i, I •. t. , t rr- i\ >l Kn-dci.. ti % ,, «. .r 't.M h. ai.i. mi. s,„
w. ,t...-I.'..v.; ' ill.! |< ...'II 1 >h- >' ,-f n
WHStEAS, with «w *2111««». - V <" ¦»" ' ' K' "ri(' ''' I1 '* r "ni ' 1 " nv' ' •'
ti.l li. . H.u V.u 1 . .Ull-WM" 1 ii vi-i • •; iw . M r.i.rv .i.U l»|i.i.v !!; Olifi*!
S"',tVeT«K
%'HKItMll.S, farther infc«f»»ti«i «mb . 1 -i*>' >i,'l ih. *» ^ »<»•>.? the
, 1..1 ,,1 Ik >. I, 1 . 11 a. \k A i i.M-.i 1.1 . ii' '.t-i ,< 11. t i' lii.i:, .1. I! x .<1 ! .ii- In*.
Divinon of Wiile i* 200 m- -ml I K .1 .Ay 40601. Records
f««f »!8| iijn papity amy I* found under TKMPO AI # I ?3i a»i Alii 111.
MOW, THBS.fi* I '1*1 'noil, 1-" I 'Ik" • H..U L-liiiMn. . > <1 < ;i n. I»
tie. ll-.l.kl vt\ .1.* °'.1. lie N-n-.r. b »» MHl by., I |. -.1
III!! I "I.,I • • u.r ,, ,,1 ' 1 'VK.I > <("' ' I'.. <.,1 „lW.M I .. I.» t
.IA.I kfclall fcll ISiaBdiriidllJA I .
>*
E-16
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(iltsljltu III lalaissl. 5
K |l,v A Hut >"'* ' H >-'11,11 ¦! ' ,• >t I' I .mi. ! or Ifiolti family
>iU,t»r T.. I ,«,.f S'-.i.r ... s-^.r.l (mm- f» mi.«» «,nI « ¦ (M.i . i
A- PiiiliifclieiJ Um*. The Property tiisit .. h. '•» ¦-» i • ""i .•v.vf
*¦,r ... _.-I if; . „ . ...iff' kb-. w Ej.-—,*,m .^n¦*> *. 1»4 t°1
1. \ It 1 I M'l I i' \ " I M'1! 4. -V /! .!' » rmikMAl
H
i . , ,,l K, "T p -if it I I I.'I I'l . 1 i..|, • .Hi- r I . ¦ i
I I EH *! ' !' t( h i
v. * **« JMt tie dtetvrM (n «gr it««liti.M
f, ' IV't'Ml IV!' ' r' ¦' 1 ' •ilwOwilW0tl(1|Wl»«!»M* MH. -I' W..r- . . •
'liii llfiBtat, K I I . 1 -I . -1. M
J
E-17
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WfcSUc
3. MffiMLmmiiima
A, Hriis.ii m toRus v uii tile I au,s Pw \rm»dv-U S i\u;,.iu fffljJ v.rwkit
wt»fcu> «nd .nfwe*". Ihc iVdJ m! ri.M»-nn^w,4»'..u-Mit .IjteJ -\«ku>i > :»«» weowtod m
fit Hail* Ceniilf Cleti'i Office Jn Oco.l i*«*4U I-w JI * ».! I v i .ml raw I '¦
KKS st.l -V-, ,n \t.iiiw>£\» |HIW« h" ih»- k-Ills .*! e»»%
•wimW I mmwiKTis! t .'.trail', ! | „r«" :I« trtih- PrafVtv .ipU-x- ..Tprr^.U i n.-J
ipflwi,hlc-nK Ii'imh jwiivi •>««' >w,,« <« "• '¦•«' lv" l"-i'
Aihlct.ij fx «*>< .Hi IV.,v.h - -Mm.. .u» > ,ii i ml, .«« iwM ir -i.o
I'r.ijN iti ,r ,t\ pan ifnih. rc<..!>! .*•(«¦> n . .... fin
i„ , C» h... > -'rt'l *m: > sU ihre. u- »
»m> or ft WA5JC Mja-I^.r.r mi fx IHrm.t, ' l» i Kp>ir » M ,ti.l
fllirly (Ji'l ii^ »lv Art'*, id i. ,1(1^.^(1)1 in ii * i I.' ' «"n.tirt«uUm
Of «K of the Property. fv'u'- **• lhf m'm mti «^T*.'rc iwmKt u tic
|i , !raii'\rw .( U..U ,! .J. | ml*. j«.u«tK-iuiH.ii tni.ltrm.i> ». (he
mmsmmwaimmm •*»,*%-»» * tMiautui
C, m>., IKrth ,bh! Uew • *-«-•« .n>irw,iiKii< hnul'tf .uiiirinw jii>
tnU'HV in I'll." I'm|ici1> m 1..V p(.rt.,.t, I.l Ik I'lHf* IW vu:i u.ftt.m.(IV »r -n<
i«;"ll|li m* M.-1 i«.Tlfi r, III'. lllH'.l W HfUMtmoiLi > ,<• ..11.UK, >.'11) |Vw Ik IIV.. .hsl
«ni^ Vwr.i'J 1 iiM-.Jin.tnn. I, .iu-n-(," 1't- imi<_ .,N1 ip. '>*< n:w! * •• V
(mm:
TIE INTEREST CONVEYED HEREBY IS SllllllCr TO »
AMEMDBD ENVTRONMENTAL COVENANT, DATEO 2?,
2017. RECORDED IN TOE C*«C«t HBCOtilS OF THE HARLAN
COUNTY CLERK'S OFFICE M DEED Mfl f AOS tjQT
D, /..IV114, ( WS0 I twi« .h>> n.rt.1* the tttae®f, Keiilnefc# DfvMaB of *«. i
M iius'cnwnl »n4 Iht IPA R.y.w 4 *.„v ... « l*».i «•. mtim «.,•».«lf
¦fflfctliin. * sj*m.iKhl ii- > a ¦ l«r 4 "jiUium pcrmr fo. ihr Out:
p..'-n Hi K^.luAi II \ • ...<1 ..1 W.Mt M^vmvnl ,m,l lhf H >Yvt,-r i i'A 4 Mi[« •»»)'.!
D'm.'.k-i , i .j... .. ^.v-,1 r IW !»r.S u. i I- ih
B. ^miplMK. >'v> ,1' ^ Jttm. w. p.,1 ,• i'., Ih ra.. -I
Hm K«u.a-. |>,»im>»>, M^ihum «.i 'K Din-cM' IM Rcgi.^ 1 SvptnmA
k«. iK ..n",iurv>^ <» Ik" tl.rt. &i- \ iWKk.t , f . sera u,. h,
Iht i r. H -ih i mrursi.-niji' <**¦- J-.i aii>. L».k ifli .|.n vv«i
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E-23
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E-24
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APPENDIX F - PRESS NOTICE
NVIRONMENTAL PROTECTION AGENCY
NEWS RELEASE
EPA.GOV/NEWSROOM
EPA to Review Cleanups at 45 Southeast Superfund Sites
Contact Information: reqion4pr6ss@epa.gov, 404-562-8400
ATLANTA (Oct. 19, 2022) - Today, the U.S. Environmental Protection Agency (EPA) announced that
comprehensive reviews will be conducted of completed cleanup work at 45 National Priority List (NPL)
Superfund sites in the Southeast.
The sites, located in Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, and
Tennessee, will undergo a legally required Five-Year Review to ensure that previous remediation efforts at
the sites continue to protect public health and the environment.
"The Southeast Region will benefit tremendously from the full restoration of Superfund sites, which can
become valuable parts of the community landscape," said EPA Region 4 Administrator Daniel
Blackmon. "The Five-Year Review evaluations ensure that remedies put in place to protect public health
remain effective overtime."
The Superfund Sites where EPA will conduct Five-Year Reviews in 2022 are listed below. The web links
provide detailed information on site status as well as past assessment and cleanup activity. Once the Five-
Year Review is complete, its findings will be posted in a final report at
https://www.epa.qov/superfund/search-superfund-five-vear-reviews.
Alabama
Alabama Army Ammunition Plant https://www.epa.gov/superfund/alabama-armv-ammunition-plant
Alabama Plating Company, Inc. https://www.epa.gov/superfund/alabama-plating-co
Mowbray Engineering Co. https://www.epa.gov/superfund/mowbrav-engineering
US NASA Marshall Space Flight Center
US Army/NASA Redstone Arsenal https://www.epa.gov/superfund/redstone-aresenal
Florida
ALARIC Area GW Plume https://www.epa.gov/superfund/alaric-area-groundwater-plume
Beulah Landfill https://www.epa.gov/superfund/beulah-landfill
Chevron Chemical Co. (Ortho Division) https://www.epa.gov/superfund/chevron-chemical-companv
Florida Petroleum Reprocessors https://www.epa.gov/superfund/florida-petroleum-reprocessors
Miami Drum Services https://www.epa.gov/superfund/miami-drum-services
Pensacola Naval Air Station https://www.epa.gov/superfund/naval-air-station-pensacola
Raleigh Street Dump https://www.epa.gov/superfund/raleiqh-street-dump
Taylor Road Landfill https://www.epa.gov/superfund/tavlor-road-landfill
Tower Chemical Co. https://www.epa.gov/superfund/tower-chemical-companv
Georgia
Alternate Energy Resources Inc. https://www.epa.gov/superfund/alternate-energv-resources
Peach Orchard & Nutrition Co. Rd PCE Groundwater Plume Site https://www.epa.gov/superfund/peach-
orchard-road-pce-plume
Powersville Site https://www.epa.gov/superfund/powersville-site
T.H. Agriculture & Nutrition Co (Albany Plant) https://www.epa.gov/superfund/t-h-agricuIture
Kentucky
A.L. Taylor (Valley of the Drums) https://www.epa.gov/superfund/al-taylor-vallev-of-drums
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Brantley Landfill https://www.epa.aov/suoerfund/brantlev-landfill
Distler Brickyard https://www.epa.aov/superfund/distler-brickvard
Distler Farm https://www.epa.gov/superfun https://www.epa.aov/superfund/lee-lane-landfilld/distler-farm
Lee's Lane Landfill https://www.epa.gov/superfund/lee-lane-landfill
National Electric Coil Co /Cooper Industries https://www.epa.aov/superfund/national-electric-coil-cooper-
industries
Tri City Disposal Co. https://www.epa.aov/superfund/tri-citv-disposal
North Carolina
ABC One Hour Cleaners https://www.epa.aov/superfund/abc-one-hour-cleaners
Aberdeen Pesticide Dumps https://www.epa.aov/superfund/aberdeen-contaminated-aroundwater
Benfield Industries, Inc. https://www.epa.aov/superfund/benfield-industries
Cherry Point Marine Corps Air Station https://www.epa.aov/superfund/cherrv-point-marine-corps
CTS of Ashville, Inc. https://www.epa.aov/superfund/cts-millsaap
GEIGY Chemical Corp (Aberdeen Plant) https://www.epa.aov/superfund/ciba-aeiav-corporation
Gurley Pesticide Burial https://www.epa.aov/superfund/aurlev-pesticide-burial
North Carolina State University (Lot 86, Farm Unit #1) https://www.epa.aov/superfund/north-carolina-state-
university
Sigmon's Septic Tank Service https://www.epa.aov/superfund/sigmon-septic-tank
South Carolina
Admiral Home Appliances https://www.epa.aov/superfund/admiral-home-appliances
Beau nit Corp (Circular Knit & Dyeing Plant) https://www.epa.gov/superfund/beaunit
Carolawn Inc. https://www.epa.aov/superfund/carolawn
Elmore Waste Disposal https://www.epa.aov/superfund/elmore-waste-disposal
International Minerals and Chemicals (IMC) https://www.epa.aov/superfund/imc
Kalama Specialty Chemicals https://www.epa.aov/superfund/kalama-speciattv-chemicals
Koppers Company, Inc. (Charleston Plant) https://www.epa.aov/superfund/koppers-charleston-plant
Savannah River Site (USDOE) https://www.epa.aov/superfund/savannah-river-site
SCRDI Bluff Road https://www.epa.aov/superfund/scrdi-dixiana
Tennessee
Mallory Capacitor Co. https://www.epa.aov/superfund/mallorv-capacitor
Memphis Defense Depot (DLA) https://www.epa.aov/superfund/memphis-defense-depot
Background
Throughout the process of designing and constructing a cleanup at a hazardous waste site, EPA's primary
goal is to make sure the remedy will be protective of public health and the environment. At many sites,
where the remedy has been constructed, EPA continues to ensure it remains protective by requiring
reviews of cleanups every five years. It is important for EPA to regularly check on these sites to ensure the
remedy is working properly. These reviews identify issues (if any) that may affect the protectiveness of the
completed remedy and, if necessary, recommend action(s) necessary to address them.
There are many phases of the Superfund cleanup process including considering future use and
redevelopment at sites and conducting post cleanup monitoring of sites. EPA must ensure the remedy is
protective of public health and the environment and any redevelopment will uphold the protectiveness of
the remedy into the future.
The Superfund program, a federal program established by Congress in 1980, investigates and cleans up
the most complex, uncontrolled or abandoned hazardous waste sites in the country and endeavors to
facilitate activities to return them to productive use. In total, there are more than 280 Superfund sites
across the Southeast.
More information:
EPA's Superfund program: https://www¦epa.qov/superfund
F-2
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APPENDIX G - INTERVIEW FORMS
NATIONAL ELECTRIC COIL CO./COOPER INDUSTRIES SUPERFUND SITE FIVE-
YEAR REVIEW INTERVIEW FORM
Site Name: National Electric Coil Co./Cooper Industries
EPA ID: KYD985069954
Interviewer name: Kirby Webster
Interviewer affiliation: Skeo
Subject name: Michael Morris, P.G.
Subject affiliation: Shield Environmental
Associates
Subject contact information: 948 Floyd Drive, Lexington, KY 40505 | (859) 294-5155
Interview date: December 1, 2022
Interview time:
Interview location: Shield Environmental Associates Office
Interview format (circle one): In Person Phone
Mail
Email
Other:
Interview category: O&M Contractor
What is your overall impression of the project, including cleanup, maintenance and reuse
activities (as appropriate)9
The EPA-approved remedial action (pump-and-treat system) continues to operate as designed.
Although COCs have appeared to reach asymptotic conditions on site, the system remains effective
in controlling off-site migration of the COCs. Although the Site continues to be used as an
automobile salvage yard, access issues noted during the last FYR have substantially improved over
the past year.
What is your assessment of the current performance of the remedy in place at the Site9
Although groundwater impacts at the Site have become asymptotic, the system continues to create a
cone of depression in the intermediate and deep aquifers and the interceptor trench appears to
remain effective in preventing contaminants in the shallow aquifer from migrating off site or to the
Cumberland River.
What are the findings from the monitoring data9 What are the key trends in contaminant levels that
are being documented over time at the Site9
As stated above, TCE concentrations in the on-site, shallow aquifer have decreased significantly
over the years and have reached asymptotic conditions over the past five years. The degradation
product 1,2-DCE has shown slight decreases and vinyl chloride has remained stable in the on-site
intermediate and deep aquifers over the last five years.
Measurable decreases of 1,2-DCE and vinyl chloride have been detected in samples collectedfrom
one off-site deep aquifer well (CMW-7) over the past five years. Concentrations of 1,2-DCE have
decreased by almost 94%, from 21.5 ng/L in June 2018 to 1.3 ng/L in December 2017. The
concentration of vinyl chloride has fluctuated between 6.08 ng/L and 36 ng/L over the same time
period. A second off-site well (CMW-12) has shown relatively consistent vinyl chloride levels over
G-l
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the last five years, fluctuating between 8.9 fj,g/L and 22.9 fig/L. CMW-7 and CMW-12 are the only
off-site wells with COCs, specifically vinyl chloride, above the MCL.
Is there a continuous on-site O&M presence? If so, please describe staff responsibilities and
activities. Alternatively, please describe staff responsibilities and the frequency of site inspections
and activities if there is not a continuous on-site O&M presence.
There is not a continuous on-site O&M presence. However, an O&M subcontractor (Total Electric)
has an office less than a half-mile from the site. Total Electric personnel have been instructed to
inspect the system at least twice per week and conduct system repairs as needed. The site occupant
(Pennington Used Parts) conducts regular grounds maintenance as needed and Shield
Environmental Associates personnel conduct other regular maintenance tasks such as pressure
washing the air stripper and greasing motors.
Have there been any significant changes in site O&M requirements, maintenance schedules or
sampling routines since start-up or in the last five years? If so, do they affect the protectiveness or
effectiveness of the remedy? Please describe changes and impacts.
There have been no significant changes to the O&M requirements, maintenance schedules or
sampling routines over the last five years. As stated earlier, access issues at the site have improved
substantially since the last FYR.
Have there been unexpected O&M difficulties or costs at the Site since start-up or in the last five
years? If so, please provide details.
A large transfer pump that moves water from the equalization tank to the low-profile air stripper
failed at the end of2021. The pump required a complete rebuild, which was delayed in part due to
labor and parts shortages at the beginning of2022. The pump has since been rebuilt and reinstalled
and is operating as designed.
Have there been opportunities to optimize O&M activities or sampling efforts? Please describe
changes and any resulting or desired cost savings or improved efficiencies.
Changes to the system, such as removal of the catalytic oxidizer and replacement of the tower
stripper with a low-profile air stripper, have resulted in reduced costs and improved the energy
efficiency. In addition, the EPA approved an amended sampling plan for the second semi-annual
monitoring event that entails only sampling wells with COCs above the MCLs with an abbreviated
report. Please note that these changes were implemented greater than five years ago. There have
been no significant changes to the O&M activities or sampling efforts over the past five years.
Do you have any comments, suggestions or recommendations regarding O&M activities and
schedules at the Site?
No additional comments or suggestions regarding the O&M activities and/or schedules.
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Do you consent to have your name included along with your responses to this questionnaire in the
FYR Report9
Yes.
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NATIONAL ELECTRIC COIL CO./COOPER INDUSTRIES SUPERFUND SITE FIVE-
YEAR REVIEW INTERVIEW FORM
Site Name: National Electric Coil Co./Cooper Industries
EPA ID: KYD985069954
Interviewer name: Kirby Webster
Interviewer affi 1 iation: Skeo
Subject name: Jeffrey P. Allen
Subject affiliation: Cooper Industries
Subject contact information: Eaton Corporation, 1000 Eaton Blvd, Cleveland, Ohio
Interview date: December 1, 2022
Interview time:
Interview location:
Interview format (circle one): In Person Phone Mail Email Other:
Interview category: Potentially Responsible Party (PRP)
What is your overall impression of the remedial activities at the Site9
The remediation system continues to function as designed. The concentrations of site COCs have
reached asymptotic conditions on site and the system continues to adequately prevent off-site
migration, with an on-site interceptor trench in the shallow aquifer and recovery wells in the
intermediate and deep aquifers.
What have been the effects of the Site on the surrounding community, if any?
To my knowledge, there have been no adverse effects of the Site on the surrounding community over
the past five years.
What is your assessment of the current performance of the remedy in place at the Site9
As stated above, the remediation system continues to operate as designed. Contaminant
concentrations on site have reached asymptotic conditions and migration off site is prevented.
Recent improvements to site access have allowed our contractors improved site access and an
additional source area assessment took place in July 2021.
Are you aware of any complaints or inquiries regarding environmental issues or the remedial action
from residents since implementation of the cleanup9
I am not aware of any complaints or inquiries from residents since implementation of the cleanup.
Do you feel well-informed regarding the Site's activities and remedial progress9 If not, how might
the EPA convey site-related information in the future9
Yes.
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Do you have any comments, suggestions or recommendations regarding the management or
operation of the Site's remedy?
The Site's current use as an automobile salvage yard can present certain restrictions when
accessing parts of the property. However, the property owner has recently cleared many of the
areas requiredfor access during the sampling and maintenance activities. Cooper and its O&M
contractor have a verbal agreement to keep specific areas of the site clear.
Do you consent to have your name included along with your responses to this questionnaire in the
FYR Report9
Yes.
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NATIONAL ELECTRIC COIL CO./COOPER INDUSTRIES SUPERFIJND SITE
FIVE-YEAR REVIEW INTERVIEW FORM
Site Name: National Electric Coil Co./Cooper Industries
EPA ID: KYD985069954
Interviewer name: Kirby Webster
Interviewer affiliation: Skeo
Subject name: Larry Tackett
Subject affiliation: KDEP
Subject contact information: 1 arryp.tackett@kv.gov | 502-782-8285
Interview date: 12/5/2022
Interview time: 11:45 a.m.
Interview location: email
Interview format (circle one): In Person Phone Mail Email Other:
Interview category: State Agency
1. What is your overall impression of the project, including cleanup, maintenance and reuse
activities (as appropriate)9
Overall, the work towards cleanup is going well. The PRPs for the Site are cooperative and
the affected population has been separatedfrom contact with COCs. The recent source
investigation should yield useful information into deciding what future remedy activities are
needed at the Site. The property's current use as a salvage yard is helping to reduce the
potential risk of soil exposure for surrounding residents. Currently, the volume of salvaged
vehicles is at a level where sampling and other remedy activities can occur, but an increase
in the amount of vehicles can hinder those activities.
2. What is your assessment of the current performance of the remedy in place at the Site9
The remedy is working. Human contact with COCs has been stopped. Analysis of the source
investigation and discussion of results by the PRPs, the EPA and the KDEP is needed to
inform further investigations or activities.
3. Are you aware of any complaints or inquiries regarding site-related environmental issues or
remedial activities from residents in the past five years9
No.
4. Has your office conducted any site-related activities or communications in the past five years9 If
so, please describe the purpose and results of these activities.
Nothing outside of the Site visit for this FYR and reviewing and archiving groundwater
reports submitted by the PRP's consultant.
5. Are you aware of any changes to state laws that might affect the protectiveness of the Site's
remedy9
No.
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6. Are you comfortable with the status of the institutional controls at the Site9 If not, what are the
associated outstanding issues9
No, there are still properties adjacent to the Site that have not signed off on the institutional
controls.
7. Are you aware of any changes in projected land use(s) at the Site9
No.
8. Do you have any comments, suggestions or recommendations regarding the management or
operation of the Site's remedy9
The use of the property as a salvage yard may be negatively impacting the site in unknown
ways. The salvaged vehicles could be leaking various fluids into the subsurface, possibly
slowing down or causing the need to alter the remedy. This possibility needs to be explored.
If found to be the case, then legal actions to add Pennington Auto Salvage as a PRP for the
Site could be warranted.
9. Do you consent to have your name included along with your responses to this questionnaire in
the FYR Report9
Yes.
G-7
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APPENDIX H - DATA REVIEW SUPPLEMENTS
Table H-l: Groundwater Monitoring Network
Groundwater Monitoring Network
2022 First Semi-Annuai Monitoring Report
National Electric Coil
Harlan, Kentucky
Monitoring Requirement
Shallow
Intermediate
Deep
T rench
R-2
CMW-5-2
BH-0*
CMW-12
CMW-5-2A
BH-1*
CMW-5-11A
CMW-5-11 *
BH-2
CMW-5-11B
CMW-5-0*
Groundwater Levels and
BH-4
CMW-6*
Ground Water Samples
R-1
CMW-7"
CMW-9*
CMW-12-t 6
CMW-13*
CMW-85*
Groundwater Level Ortly
BH-3 (Dry)
BH-5 (Dry)
CMW-12A
* Annual Groundwater Sampling required per EPA's July 28, 2006 Approval Letter
** Duplicate Collected for QA/QC purposes
Source: Tabic 4 of the 2022 First Scmi-Annual Monitoring Report (PDF page 44).
Table H-2: Oil-Site Well Exceedances - Senii-Annual Groundwater, 2018 to 2022
Well
Date
Contaminant
TCE
1,2-DCE (total)
Vinyl Chloride
Benzene
MCL = 5 p.g/L
MCL = 70 jig/L
MCL = 2 u«/L
MCL = 5 ng/L
Shallow Monitoring Wells
Trench
7/9/2018
595
—
—
—
12/19/2018
1,010
—
—
—
6/12/2019
857
—
—
—
12/11/2019
39.7
—
—
—
12/8/2020
630
—
—
—
6/23/2021
970
—
—
—
R-1
7/9/2018
3,630
—
—
—
12/19/2018
6,290
—
—
—
6/12/2019
2,220
—
—
—
12/11/2019
44
—
—
—
12/8/2020
11
—
—
—
6/23/2021
32
—
—
—
12/15/2021
320
—
—
—
6/29/2022
120
—
—
—
BH-2
6/19/2018
13.5
—
—
—
12/18/2018
14.1
—
—
—
6/12/2019
13.5
—
—
—
12/10/2019
8.55
—
—
—
12/8/2020
14
—
—
—
6/22/2021
15
—
—
—
12/15/2021
12
—
—
—
6/28/2022
13
—
—
—
BH-4
6/19/2018
115
—
—
—
12/18/2018
53.3
—
—
—
6/12/2019
47.9
-
-
-
H-l
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12/10/2019
36.9
—
5.07
—
12/8/2020
27
—
8.1
—
6/22/2021
7.5
—
—
—
12/15/2021
27
—
—
—
6/28/2022
14
—
—
—
Intermediate Monitoring Wells
R-2
6/20/2018
46.6
677.7
26.6
—
12/19/2018
29.3
658
21.9
—
6/12/2019
14.6
672
18.9
—
12/11/2019
35
668
28.6
—
12/8/2020
42
582.7
25
—
6/23/2021
14
563
15
—
CMW-5-11B
6/19/2018
—
1,320
111
—
12/18/2018
—
1,910
218
—
6/12/2019
—
1,790
153
—
12/10/2019
—
1,690
195
19.5
12/80/2020
—
1,704
120
17
6/22/2021
—
1,417
170
16
12/15/2021
—
1,504
110
9.5
6/28/2022
—
1,304
100
10
CMW-5-11A
6/19/2018
14
1,770
34
—
12/18/2018
51.1
1,970
54.7
—
6/12/2019
66.9
1,620
52
—
12/10/2019
70.2
1,522
58.1
—
12/8/2020
98
1,608
32
—
6/22/2021
41
1,635
59
—
12/15/2021
14
1,500
34
—
6/28/2022
—
1,100
60
—
Notes:
-- = value does not exceed the MCL.
Source: Excel file received from EPA RPM Craig VanTrees on 10/18/2022.
Table H-3: Off-Site Well Exceedances - Semi-annual Groundwater Sampling Events, 2018 to 2022
Well
Date
Contaminant
TCE
1,2-DCE (total)
Vinyl Chloride
MCL = 5 |ig/L
MCL = 70 jig/L
MCL = 2 ng/L
Intermediate Monitoring Wells
CMW-12
6/19/2018
--
—
8.96
12/18/2018
—
—
22.9
6/18/2019
—
—
9.37
12/10/2019
—
—
15.3
12/8/2020
—
—
12
6/22/2021
—
—
18
12/15/2021
—
—
19
6/28/2022
—
—
8.9
Deep Monitorin
g Wells
CMW-85
6/12/2019
10.5
—
—
CMW-7
6/19/2018
—
—
19.5
12/18/2018
—
—
6.08
6/12/2019
—
—
10.8
12/10/2019
—
—
12.6
12/8/2020
—
—
32
6/22/2021
—
—
33
12/15/2021
—
—
7.3
6/28/2022
—
—
36
CMW-9
6/12/2019
-
-
2.66
H-2
-------
6/28/2022
—
2.4
CMW-5-2A
6/20/2018
—
135
27.4
12/19/2018
—
132
25.8
6/12/2019
—
90.9
24.9
12/11/2019
106
33.5
12/8/2020
—
87.6
24
6/23/2021
—
78
34
Notes:
— = value does not exceed the MCL.
Source: Excel file received from EPA RPM Craig VanTrees on 10/18/2022.
Figure H-l: Recovery Well CMW-5-2A VOC Concentrations Versus Time
1
\
k\
\\
\
1 1X. *
J' .N. A
| | System Not Operating
1 A \/\
1 V \ A \
1 < \/\ \
¦L
/|
I \
i i
i v\
/ ' ¦ A
V %
X'A
A
, 7TTl>r iV-iti ",'I f. A.'t. i*rrTr>
m
,
-
nr.7 '»ill h; ~r,i
S'S,S,J?S'5BlSlS'S'S'S'S'SfS!S'S'S1S,SlS'S'5?S'S?S'SfS?S!S'?
llllzllllllglgllggllllllllil it
-ANJU)fe.ui£D-sjcDteo-»K>uiA.aicr)-JaDioo-ilvjOJfc.tnon-ja:«3 0
Source: Figure 11 of the 2022 First Semi-Annual Monitoring Report (PDF page 31).
Figure H-2: Recovery Well R-2 VOC Concentrations Versus Time
—-
2500
SntomNm
15C0
1000
500
0
/
™ ^
\ ¦-
"•—¦ \ --I
-
/
/
w
^ •--/
V-
* ~m. —¦ «
^TrrTrrrrrrti rrv;
\rt ,*t , 1. ¦ I. .-r-n--.<7 7\ 7
TVf -, t ¦¦ ¦> i ¦¦ ,, w
sep-97 Sep-58 Sep-99 sep-ra sep-ot Geo-02 sep-03 sep-w SesKJS sep-05 sep-D7 sepH3g sep-09 sep-to sep-it sep-12 Sep-53 sep-14 sep-15 sep-t6 sep-17 sep-18 3ep-i9 sep-2D
Source: Figure 13 of the 2022 First Semi-Annual Monitoring Report (PDF page 33).
H-3
-------
Figure H-3: Recovery Well CMW-5-11 VOC Concentrations Versus Time
1500
1400
1300
1200
1100
1000
on
UIXJ
s
a
a do
e
700
S
C
600
a
500
400
300
200
100
0
* Ifayt ChkjMm —¦— 1 ;fcrtrfi
* TidncAra — —W. SyltKTl ;ii> CK'itir^
; a\ ~
System Not Operating
If I \
/ U .
! 1 vx
\ \
•A " i
k
^ f CDeojjCiecjZ©ec^£^-OCe<:-QE«:-iI!Cec-OE^-DBec-C©ec-'0eo-'C'ec-'E'ec-"©ec-1€)ec-1E€c-1Cec-1Bec-1Eiec-1Wo,^2®ic'/-2t
Source: Figure 12 of the 2022 First Semi-Annual Monitoring Report (PDF page 32).
Figure H-4: Interceptor Trench/Sump VOC Concentrations Versus Time
^ ns
"" \ /A
\ f \
\ \ / \ l\
U A /
-l \
\ \/ \ J\
/ ^ X / V
\ / \ / x \ ^
^ \ y '
—¦ - r » — ~i—<¦—r~t t~i*-;—ri-.—r». , ¦> ¦ 1 ¦ «r».
—/
\
>
¦
>
f2SOO
i
I aw
Source: Figure 14 of the 2022 First Semi-Annual Monitoring Report (PDF page 34).
Figure H-5: Monitoring Well CMW-7 VOC Concentrations Versus Time
1200
1000
_ 800
%
_3_
§
'I 600
C
8
g
o
o
'4
i
f / >
I r
T1 "
\
_y
!M
A"
I System Not
Operating
V
*« ' fIrt
• I I I «i« t " i f ¦ Ifc I ¦
Dec-9'. Dec-92 Dec-83 Dec-&4 Dec-95 Dec-93 Dec-97 Dec-08 Dec-SS Dec-OD Dec-01 Dec-02 Deo03 Dec-04 Dec-Dc Deo05 Dec-07 Dec-OS Dec-09 Dec-!G Dec-t1 Dec-12 Dec-53 Dec-14 Dec-15 Dec-«9 Deo 17 Dec-18 Dec-!9 Nov-20 Ntov-21 Nov-22
Source: Figure 15 of the 2022 First Semi-Annual Monitoring Report (PDF page 35).
H-4
-------
Figure H-6: Monitoring Well CMW-12 VOC Concentrations Versus Time
250
Jan-93Jan-94Jan-95Jarv96Jan-97Jan-98Jarv99Jarv00Jai>-01Jan-O2Jan-03JarvO4Jarv05Jarv-06Jan-07Jan-08Jaiv09Jan-10Jarv11Jar>-12Jan-13Jarv14Jan-15Jaiv16Jan-17Jan-18Jaiv19Jarv2QJarv21Jan-22
Source: Figure 16 of the 2022 First Semi-Annual Monitoring Report (PDF page 36).
Figure H-7: Monitoring Well CMW-85 VOC Concentrations Versus Time
Monitoring Well CMW-85, VOC Concentrations Versus Time
National Electric Coil Facility
Harlan. Kentucky
Deo-91 Dec-92Dec-63Dec-94Dec-QEDec-86Dec-97Dec-98Deo99Dec-00Dec-D1 Dec-Q2Dec-O3Dec-Q4Dec-O5Dec-O6Dec-O7Dec-C8Dec-Q0Dec-lODec-11 Deo-12Dec-13Dec-14Dec-15Dec-t6Deo-17Dec-18Dec-19Nov-20Nov-21Nov-22
Source: Figure 17 of the 2022 First Semi-Amiual Monitoring Report (PDF page 37).
H-5
-------
Figure H-8: Cumulative VOC Recovery
4,000
3,500
3,000
Source: Figure 18 from the 2022 First Seini-Annual Monitoring Report (PDF page 38).
Figure H-9: Soil Boring/Temporary Assessment Well Locations Map
L£.
«3 ALUA1M. MMFEJi iB.L L0CA1HN5
* INTCSMEMTE BERCCK «XIFE? R0BWRV *QL LOCMIOt
» INimEaXIE MLIFEH «Qi LOCATIONS
* ICE? :ECfit»IK MUFEP SECOVEHT AtLL LC«^T»45
* 3EFOa< AQUIS! *Q1 WCMIWS
4 SOL fiOfilHG / TDJPCIWiY #SES4CKT AtLL LOOUCNS
\
\
\
\
\
\\
J L
r-i
\
,r——
o
S3
?=!
•rJ
%
*5^
§ IS
Ml
s s |i
it S
z> H
-------
LEGEM*
,. ALLlMM. MMFER «£LL UX>TKJNS
IMTftUElATE BEDSOCK *^FE=! RECOVERY «QI LOCAT1C
• INTERMECIA1E MUFER "ELL LCCATICKS
• :&? SEWOCK AQUFEP SECOvOT *B1 IDCATKW5
• 9EWCK* AQUfB» "Eli LOMTIOHS
4 53L BOHHG / TDfPOB«Y ASS5SVCKT AELL LOCATIONS
m HKK5T KE C0KCEH1RATKS* IK SSL KWHG
"X'
I
±±
r-i
\ \
\
\
-CZ3-
\
gj
S?8
IS
111
10 i oi
111 p U|3
* gl
o gr
UJ CC t
g Ig
Sil
sj
Source: Figure 5 from the Source Area Assessment Report (PDF page 24).
Figure 11-11: Groundwater TCE Isoconcentration Map
Source: Figure 6 from the Source Area Assessment Report (PDF page 25).
H-7
-------
Figure H-12: Indoor Air and Sub-Slab Sampling Locations
Sub Slab TCE Concentrations (jig/m3)
-J
?ls
Si
' ¦
* '
'"Til
to
"J*
L£GEM) \,
& ALUA1W- AQUIFER "ELL LOCATIONS
MEHwEDlATE AQUFEU RECOVERY «IL LOCaUEH \
* INTERNEEUTE AQUIFER *Qi LQCAH0N5
* OEEP 3EDR0CK MUFBt AED3VEHY *ELL LOCATBKS \
• SEOftOCK AQUIFER <€LL UXAIJOHS
O IWOOR AIR SMJPUKG LOCATIONS
• SJB—SLA9 SAWPLHC LOCATIONS \
"W Pm ' —
11
Source: Figure 4 from the Vapor Intrusion Pathway Assessment Report (PDF page 21).
H-8
-------
Figure H-13: Statistical Analyses
R-l TC E concentration December 2017-December 2022
7000
6000
5000
40®®
H
i
a
o
t 3000
CS
a
2000
1000
\
%
\
\
X
\
\
\
\
%
its
\
v
\
\
\
%
%
\
\
5 «s*/l
. j
cleanup
level
May-16 Sep-17 Feb-19 .Juu-20 Oct-21 Mm-23 Jul-24 Dec-25 Api-2" Sep-2S Jan-30
H-9
-------
BH-4 TCE concentration December 2017-December 2022
140.00
120.00
100.00
80.00
60.00
40.00
20.00
0.00
May 16 Sep 17 Feb 19 Jim-20 Oct 21 Mar 23 Jul 24 Dec 25
H-10
V|r
An
X
/ \
0 \
\
tl«
V
X
X
V
V
X
>uc1 line basec
ou uouparan
iiefric slope e?
timate
\
X
X
X
X
X
X
X
X
X
Xt
I
X
X
X
X
X
X
X
X
X
X
A /
\
X
X
X
X
X
X
X
X
X
X
5 ugIL clea
uup level
Y
N&—0
X
X
X
X
X
X
1
-------
R-2 cis 1,2-DCE concentration December 2017-December 2022
r\
V
X
X
X
V
X
V
X
trend line ba?
i
V
iedon nonparai
uetiic slope esti
mate
I
x
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
- 70 ug/L clean
>
X
X
X
X
X
X
X
X
May-16
Oct 21
Apr-27
Oct 32
Apr-38
Sep 43
Mar
H-ll
-------
CMW-5-11A TCE concentration
December 2017-December 2022
H-12
-------
CMW-5-11A cis 1,2-DCE concentration
December 2017-December 2022
/
*
o
\ ti
X
end line bf
sed on uoi
lparametr
ic slope est
iniate
1
V
-N
70 ug/L
cleanup le\
el
May-16 Feb-19 Oct-21 Jul-24 Apr-27 Jaii-30 Ocf-32 Jill 35 Apr-38 Dec-40
H-13
-------
CMW-5-11A Vinyl Chloride concentration
December 2017-December 2022
V
%
A
\
\/
\
V
»
\
rend liue
loiipararu
based oil
etric slop
eestimat
\ 1
e
%
2 ug/L
leamip le
vel
V
May-16 Sep-17 Feb-19 Juii-20 Oct 21 Mar-23 Jiil-24 Dec-25 Apr-27 Sep 28 Jan-30
H-14
-------
CMW-5-2A cis 1,2-DCE concentration
December 2017-December 2022
tienfl
line based oil u
Dnparanietric si
ope estimate _
/
70 ug/L cleani
0
V "
XT'
tp level
\
\
\
\>
May-16
Sep-17
Feb-19
Ju n-20
Oct-21
Mar-23
Jul-24
H-15
-------
CMW-5-2A Vinyl Chloride concentration
December 2017-December 2022
\ K
I
4
V \
\
ased on
trie slope esti
trend line b
nonparame
mate
2 ug/L cleai
lup level
^
Dec-14 Sep-17
Jun-20
Mar-23
Dec-25 Sep-28 Juii-31
Feb-34
H-16
-------
APPENDIX I - SITE INSPECTION CHECKLIST
FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST
I. SITE INFORMATION
Site Name: National Electric Coil Co./Cooper
Industries
Date of Inspection: 11/16/2022
Location and Region: Dayhoit, Kentucky 4
EPA ID: KYD985069954
Agency, Office or Company Leading the Five-Year
Review: EPA
Weather/Temperature: Sunnv/~40° F
Remedy Includes: (check all that apply)
~ Landfill cover/containment
~ Access controls
Institutional controls
[3 Groundwater pump and treatment
~ Surface water collection and treatment
E Other: Emissions controls on air stream leaving the air stripper tower.
~ Monitored natural attenuation
~ Groundwater containment
~ Vertical barrier walls
Attachments: d Inspection team roster attached
O Site map attached
II. INTERVIEWS (check all that apply)
1. O&M Site Manager Michael Morris. P.G. Project Manager 12/01/2022
Name Title Date
Interviewed ~ at site ~ at office by email Phone: 859-294-5155
Problems, suggestions ~ Report attached: See Appendix G.
2. O&M Staff ~~~~~ ~~~~~ ~~~~
Name Title
Interviewed ~ at site ~ at office ~ by phone Phone:
Problems/suggestions ~ Report attached:
Date
3. Local Regulatory Authorities and Response Agencies (i.e., state and tribal offices, emergency
response office, police department, office of public health or environmental health, zoning office,
recorder of deeds, or other city and county offices). Fill in all that apply.
Agency KDEP
Contact Larry Tackett Project
Name Manager
Title
Prob le ins/suggest io ns IE1 Report attached: See Appendix G.
12/05/2022
Date
502-782-8285
Phone
Agency.
Contact
Name
Title
Date
Phone
Prob le ins/suggest io ns ~ Report attached:.
Agency
Contact
Name Title
Prob le ins/suggest io ns ~ Report attached:
Date
Phone
Agency
Contact
Name Title
Prob le ins/suggest io ns ~ Report attached:
Date
Phone
1-1
-------
Agencv
Contact
Name Title
Problems/suggestions [~~| Report attached:
Date
Phone
4.
Other Interviews (optional) Ex] Report attached: See Appendix G.
Jeffrey P. Allen (Cooper Industries - PRP)
III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)
1.
O&M Documents
13 O&M manual Readily available
^1 Up to date
~ N/A
[3 As-built drawings ^ Readily available
^ Up to date
~ N/A
[3 Maintenance logs ^ Readily available
^ Up to date
~ N/A
Remarks:
2.
Site-Specific Health and Safety Plan
^ Readily available
13 Up to date
~ n/a
~ Contingency plan/emergency response plan
13 Readily available
13 Up to date
~ n/a
Remarks:
3.
O&M and OSHA Training Records
Remarks:
^ Readily available
13 Up to date
~ n/a
4.
Permits and Service Agreements
~ Air discharge permit
~ Readily available
~ Up to date
13 N/A
13 Effluent discharge
^ Readily available
13 Up to date
~ n/a
~ Waste disposal. POTW
~ Readily available
~ Up to date
13 N/A
n Other Dcrmits:
~ Readily available
~ Up to date
13 N/a
Remarks:
5.
Gas Generation Records
Remarks:
~ Readily available
~ Up to date
13 N/A
6.
Settlement Monument Records
Remarks:
~ Readily available
~ Up to date
13 N/A
7.
Groundwater Monitoring Records
Remarks:
^ Readily available
13 Up to date
~ n/a
8.
Leachate Extraction Records
~ Readily available
~ Up to date
13 N/A
Remarks:
9.
Discharge Compliance Records
13 Air ^ Readily available
^ Up to date
~ N/A
13 Water (effluent) ^ Readily available
^ Up to date
~ N/A
Remarks:
10.
Daily Access/Security Logs
~ Readily available
~ Up to date
13 N/A
1-2
-------
Remarks:
IV. O&M COSTS
1.
O&M Organization
[~l State in-housc
~ Contractor for state
1 1 PRP in-housc
1X1 Contractor for PRP
l~l Federal facility in-house
O Contractor for Federal facility
~
2.
O&M Cost Records
l~l Readily available
O Up to date
l~l Funding mechanism/agreement in place ^ Unavailable
Original O&M cost estimate:
~ Breakdown attached
Total annual cost by year for review period if available
From: To:
n Breakdown attached
Date Date
Total cost
From: To:
n Breakdown attached
Date Date
Total cost
From: To:
n Breakdown attached
Date Date
Total cost
From: To:
n Breakdown attached
Date Date
Total cost
From: To:
n Breakdown attached
Date Date
Total cost
3.
Unanticipated or Unusually High O&M Costs during Review Period
Describe costs and reasons:
V. ACCESS AND INSTITUTIONAL CONTROLS ^ Applicable ~ N/A
A. Fencing
1.
Fencing Damaged ~ Location shown on site map [3 Gates secured ~ N/A
Remarks: Fencing appeared in good condition. The entire site property is fenced.
B.
Other Access Restrictions
1.
Signs and Other Security Measures
~ Location shown on site map [3 N/A
Remarks:
C.
Institutional Controls (ICs)
1-3
-------
1996. Implementation and Enforcement
Site conditions imply ICs not properly implemented
[H Yes
No
~ N/A
Site conditions imply ICs not being fully enforced
~ Yes
El
No
~ N/A
Type of monitoring (e.g.. self-reporting, drive bv):
Freciuencv:
Responsible partv/agencv:
Contact
Name Title
Date
Phone
Reporting is up to date
[~l Yes
~
No
IKlN/A
Reports arc verified by the lead agency
l~l Yes
~
No
0N/A
Specific requirements in deed or decision documents have been met
l~l Yes
m
No
~ n/a
Violations have been reported
[~l Yes
No
~ n/a
Other problems or suggestions: ~ Report attached
2. Adequacy ~ ICs arc adequate [3 ICs arc inadequate ~ N/A
Remarks: The restrictive covenants on parcel 53 and parcel 54 have been completed but the institutional
controls are not vet finalized and signed by all affected property owners. The PRP. the EPA and the
KDEP are in the process of getting all affected property owners to sign inutallv agreeable restrictive
covenants. Ongoing source investigations underneath the building have identified more soil
contamination. Given that there is not a completed exposure pathway because of the building foundation,
this is not a current protectiveness issue. However, additional investigations and discussions about
potential remedial investigations may result in the need for soil institutional controls.
D. General
1. Vandalism/Trespassing ~ Location shown on site map ^ No vandalism evident
Remarks:
2. Land Use Changes On Site ^ N/A
Remarks:
3. Land Use Changes Off Site [3 N/A
Remarks:
VI. GENERAL SITE CONDITIONS
A. Roads ^ Applicable ~ N/A
1. Roads Damaged ~ Location shown on site map [3 Roads adequate ~ N/A
Remarks:
B. Other Site Conditions
Remarks:
VII. LANDFILL COVERS ~ Applicable ^ N/A
A. Landfill Surface
1. Settlement (low spots) ~ Location shown on site map ~ Settlement not evident
Area extent: Depth:
Remarks:
1-4
-------
2.
Cracks
l~l Location shown on site map
O Cracking not evident
Lengths:
Widths:
Depths:
Remarks:
3.
Erosion
Area extent:
Remarks:
l~l Location shown on site map
O Erosion not evident
Depth:
4.
Holes
Area extent:
Remarks:
~ Location shown on site map
~ Holes not evident
Depth:
5.
Vegetative Cover
l~l Grass
O Cover properly established
fl No signs of stress
[~l Trees/shrubs (indicate si/e and locations on a diagram)
Remarks:
6.
Alternative Cover (e.g., armored rock, concrete)
~ N/A
Remarks:
7.
Bulges
Area extent:
Remarks:
~ Location shown on site map
~ Bulges not evident
Height:
8.
Wet Areas/Water Damage
~ Wet areas/water damage not evident
[~l Wet areas
~ Location shown on site map
Area extent:
[~l Ponding
~ Location shown on site map
Area extent:
l~l Seeps
O Location shown on site map
Area extent:
l~l Soft subgrade
O Location shown on site map
Area extent:
Remarks:
9.
Slope Instability
O Slides
~ Location shown on site map
~ No evidence of slope instability
Area extent:
Remarks:
B.
Benches ~ Applicable ~ N/A
(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in
order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)
1.
Flows Bypass Bench
Remarks:
l~l Location shown on site map
l~l N/A or okay
2.
Bench Breached
Remarks:
[~l Location shown on site map
[~l N/A or okay
3.
Bench Overtopped
Remarks:
[~l Location shown on site map
[~l N/A or okay
1-5
-------
c.
Letdown Channels ~ Applicable ~ N/A
(Channel lined with erosion control mats, riprap, grout bags or gabions that descend down the steep side
slope of the cover and will allow the runoff water collected by the benches to move off of the landfill
cover without creating erosion gullies.)
1.
Settlement (Low spots) ~ Location shown on site map
~ No evidence of settlement
Area extent:
Depth:
Remarks:
2.
Material Degradation ~ Location shown on site map
~ No evidence of degradation
Material tvoe:
Area extent:
Remarks:
3.
Erosion ~ Location shown on site map
~ No evidence of erosion
Area extent:
Depth:
Remarks:
4.
Undercutting ~ Location shown on site map
~ No evidence of undercutting
Area extent:
Depth:
Remarks:
5.
Obstructions Tvoe:
n Location shown on site man Area extent:
Size:
Remarks:
~ No obstructions
6.
Excessive Vegetative Growth Tvoe:
~ No evidence of excessive growth
~ Vegetation in channels docs not obstruct flow
n Location shown on site man Area extent:
Remarks:
D.
Cover Penetrations ~ Applicable ~ N/A
1.
Gas Vents ~ Active
[~l Passive
[~l Properly secured/locked ~ Functioning O Routinely sampled ~ Good condition
[~l Evidence of leakage at penetration O Needs maintenance ~ N/A
Remarks:
2.
Gas Monitoring Probes
l~l Properly secured/locked Q Functioning O Routinely sampled O Good condition
l~l Evidence of leakage at penetration O Needs ma
mtenance O N/A
Remarks:
3.
Monitoring Wells (within surface area of landfill)
l~l Properly secured/locked Q Functioning ~ Routinely sampled O Good condition
[~l Evidence of leakage at penetration O Needs maintenance ~ N/A
1-6
-------
Remarks:
4.
Extraction Wells Leachate
l~l Properly secured/locked Q Functioning O Routinely sampled O Good condition
l~l Evidence of leakage at penetration O Needs maintenance O N/A
Remarks:
5.
Settlement Monuments Q Located O Routinely surveyed O N/A
Remarks:
E.
Gas Collection and Treatment ~ Applicable ~ N/A
1.
Gas Treatment Facilities
[~l Flaring O Thermal destruction ~ Collection for reuse
[~l Good condition O Needs maintenance
Remarks:
2.
Gas Collection Wells, Manifolds and Piping
[~l Good condition ~ Needs maintenance
Remarks:
3.
Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)
[~l Good condition ~ Needs maintenance ~ N/A
Remarks:
F.
Cover Drainage Layer ~ Applicable ~ N/A
1.
Outlet Pipes Inspected Q Functioning ~ N/A
Remarks:
2.
Outlet Rock Inspected ~ Functioning ~ N/A
Remarks:
G.
Detention/Sedinientation Ponds ~ Applicable ~ N/A
1.
Siltation Area extent: Depth: [~~l N/A
O Siltation not evident
Remarks:
2.
Erosion Area extent: Depth:
~ Erosion not evident
Remarks:
3.
Outlet Works Q Functioning ~ N/A
Remarks:
4.
Dam Functioning O N/A
Remarks:
EL Retaining Walls ~ Applicable ~ N/A
1.
Deformations ~ Location shown on site map O Deformation not evident
1-7
-------
Horizontal displacement: Vertical displacement:
Rotational displacement:
Remarks:
2.
Degradation ~ Location shown on site map
Remarks:
l~l Degradation not evident
I. Perimeter Ditches/Off-Site Discharge ~ Applicable
~ N/A
1.
Siltation ~ Location shown on site map
[~l Siltation not evident
Area extent:
Depth:
Remarks:
2.
Vegetative Growth ~ Location shown on site map
~ Vegetation does not impede flow
~ n/a
Area extent:
Tvpe:
Remarks:
3.
Erosion ~ Location shown on site map
[~l Erosion not evident
Area extent:
Depth:
Remarks:
4.
Discharge Structure ~ Functioning
Remarks:
~ n/a
VIII. VERTICAL BARRIER WALLS ~ Applicable
13 N/A
1.
Settlement O Location shown on site map
l~l Settlement not evident
Area extent:
Depth:
Remarks:
2.
Performance Monitoring Tvpe of monitoring:
O Performance not monitored
Frcauencv:
[~l Evidence of breaching
Head differential:
Remarks:
IX.
GROUNDWATER/SURFACE WATER REMEDIES Applicable ~ N/A
A. Groundwater Extraction Wells, Pumps and Pipelines
^ Applicable ~ N/A
1.
Pumps, Wellhead Plumbing and Electrical
[3 Good condition All required wells properly operating ~ Needs maintenance Q N/A
Remarks: During the first six months of 2022. the groundwater recovery svstem was not operational due
to a pump failure. The pump was removed and sent to an electrical subcontractor to be rebuilt. In Mav
2022. the rebuilt pump was reinstalled. The pump operated for about two weeks before an electrical
malfunction in the svstem caused the pump to burn out and reauired a second rebuild. The rebuilt pump
was received and reinstalled in Julv 2022. The svstem has been operating as designed since then.
2.
Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances
^ Good condition ~ Needs maintenance
1-8
-------
Remarks:
3.
Spare Parts and Equipment
[x] Readily available ^ Good condition O Requires upgrade Q Needs to be provided
Remarks:
B. Surface Water Collection Structures, Pumps and Pipelines ~ Applicable ^ N/A
1.
Collection Structures, Pumps and Electrical
~ Good condition ~ Needs maintenance
Remarks:
2.
Surface Water Collection System Pipelines, Valves, Valve Boxes and Other Appurtenances
~ Good condition ~ Needs maintenance
Remarks:
3.
Spare Parts and Equipment
~ Readily available ~ Good condition ~ Requires upgrade ~ Needs to be provided
Remarks:
C.
Treatment System ^ Applicable ~ N/A
1.
Treatment Train (check components that apply)
~ Metals removal ~ Oil/water separation ~ Biorcinediation
[>2 Air stripping O Carbon adsorbers
n Filters:
n Additive (e.g.. chelation agent, flocculent):
n Others:
E3 Good condition Q Needs maintenance
E3 Sampling ports properly marked and functional
E3 Sampling/maintenance log displayed and up to date
E3 Equipment properly identified
Ex] Ouantitv of groundwater treated annuallv:
n Ouantitv of surface water treated annuallv:
Remarks:
2.
Electrical Enclosures and Panels (properly rated and functional)
~ N/A E3 Good condition ~ Needs maintenance
Remarks:
3.
Tanks, Vaults, Storage Vessels
~ N/A E3 Good condition ~ Proper secondary containment ~ Needs maintenance
Remarks:
4.
Discharge Structure and Appurtenances
~ N/A E3 Good condition ~ Needs maintenance
Remarks:
1-9
-------
5.
Treatment Building)*)
O N/A 1^ Good condition (csp. roof and doorways) O Needs repair
O Chemicals and equipment properly stored
Remarks:
6.
Monitoring Wells (pump and treatment remedy)
[x] Properly secured/locked ^ Functioning ^ Routinely sampled ^ Good condition
All required wells located £3 Needs maintenance ~ N/A
Remarks: Wells arc generallv in good condition. The top of well CMW-7. located in a residential vard.
has been damaged and mav need to be repaired.
D. Monitoring Data
1.
Monitoring Data
Is routinely submitted on time ^ Is of acceptable quality
2.
Monitoring Data Suggests:
E3 Groundwater plume is effectively contained [3 Contaminant concentrations arc declining
E.
Monitored Natural Attenuation
1.
Monitoring Wells (natural attenuation remedy)
~ Properly secured/locked ~ Functioning ~ Routinely sampled ~ Good condition
O All required wells located Q Needs maintenance N/A
Remarks:
X. OTHER REMEDIES
If there arc remedies applied at the site and not covered above, attach an inspection sheet describing the physical
nature and condition of anv facilitv associated with the rcmcdv. An example would be soil vapor extraction.
XI. OVERALL OBSERVATIONS
A.
Implementation of the Remedy
Describe issues and observations relating to whether the remedy is effective and functioning as designed.
Begin with a brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant
plume, minimize infiltration and gas emissions).
During the 1991 removal action, contaminated soils were excavated and removed from the Site and
replaced with clean fill. Residents arc connected to the public water supplv. and no one is currcntlv using
the groundwater at the Site. The groundwater remediation svstem continues to remove VOCs from the
various aciuifers. However, mass removal rates arc slowing and optimization mav be needed. The source
assessment in 2021 confirmed that there is a significant source of contaminants present near well R-l. The
EPA is reviewing the results of this source assessment and will work with the PRP to determine if the
water treatment svstem and/or rcmcdv needs to be optimized.
B.
Adequacy of O&M
Describe issues and observations related to the implementation and scope of O&M procedures. In
particular, discuss their relationship to the current and long-term protcctivcness of the remedy.
O&M activities arc ongoing and conducted in accordance with the Site's amended 2012 O&M Plan. The
O&M contractor is on site once a week. During the first six months of 2022. the svstem was not
operational due to a pump failure. The svstem was fixed and has been operating since Julv 2022. As
mentioned, contaminant levels arc decreasing, but at a slow rate.
C.
Early Indicators of Potential Remedy Problems
Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
frequency of unscheduled repairs that suggest that the protcctivcness of the rcmcdv may be compromised
in the future.
There arc no issues or observations to be made from the O&M activities that suggest that the rcmcdv mav
be compromised in the foreseeable future. Final institutional controls arc still not in place for the mobile
home park propertv and the site propertv.
I-10
-------
D. Opportunities for Optimization
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
The remedy is acting slowly to remediate the contamination. The remedy should be reviewed to determine
if there is a way to optimize contaminant removal to reduce cleanup time. The investigation of the
possible source area near well R-l has been completed. The EPA is reviewing the results of this source
assessment and will work with the PRP to determine if the water treatment system and/or remedy needs to
be optimized.
1-1 1
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APPENDIX J - SITE INSPECTION PHOTOS
Entrance to the Site, facing east
Inside the main plant building
J-l
-------
Missing/broken windows inside the main plant building
Air stripper tower
-------
The Cumberland River, from the Holiday Acres Mobile Home Park
J-3
-------
Sub-slab monitoring point in the main building
CMW-85
J-4
-------
Interceptor trench
J-5
-------
APPENDIX K - DETAILED ARARS REVIEW TABLES
CERCLA Section 12 l(d)( 1) requires that Superfund remedial actions attain "a degree of cleanup of
hazardous substance, pollutants, and contaminants released into the environment and control of further
release at a minimum which assures protection of human health and the environment." The remedial
action must achieve a level of cleanup that at least attains those requirements that are legally applicable
or relevant and appropriate. In performing the FYR for compliance with ARARs, only those ARARs
that address the protectiveness of the remedy are reviewed.
Groundwater ARARs
The 1996 ROD established cleanup goals for groundwater COCs based on federal MCLs, except for
1,1,2,2-tetrachloroethane. For 1,1,2,2-tetrachloroethane cleanup goals, the practical quantitation limit
was used, which equals a risk level of 5.9 x 10"5 for a lifetime residential scenario (at the time of the
1996 ROD); this criterion is evaluated further in Appendix L. The EPA identified Safe Drinking Water
Act MCLs as ARARs for groundwater. Table K-l compares the ROD cleanup goals to current
standards. Table K-l shows that the standards for groundwater COCs have not changed.
Stack Emission Rates
The 1996 ROD established performance standards to place limitations on the discharge of TCE, cis-1,2-
DCE and vinyl chloride from the treatment system into the air. For TCE and vinyl chloride, the emission
rates were based on risk-based levels; this criterion is evaluated further in Appendix L. An IIJR has not
been derived for cis-l,2-DCE. Therefore, the emission rate was based on 401 KAR 63:022. KAR 63:022
no longer exists and therefore could not be compared to current standards.6
Table K-l: Groundwater ARARs Review
coc
1996 ROD Cleanup Goal"
(MU/L)
Current Standard (|.i*»/L)h
Change
1.1-DCE
7
7
None
Cis-1,2-DCE
70
70
None
Trans-1.2-DCE
100
100
None
TCE
5
5
None
Vinvl chloride
2
2
None
Notes:
a. The source is Table 9.1 of the 1996 ROD (PDF page 57)
b. National primary drinking water regulations arc the source: httDs://www.eDa.gov/ground-water-and-drinking-
water/natiorial-Dri ma rv-drinking-water-regulations (accessed 12/16/2022).
6 Title 401 KAR Chapter 063 Regulation 022: https://apps. legislature ,kv.gov/law/kar/titIes/401 /063/022 (accessed 1/6/2023).
K-l
-------
APPENDIX L - SCREENING-LEVEL AND VAPOR INTRUSION RISK
REVIEW
Groundwater
The 1996 ROD established the cleanup goal for 1,1,2,2-tetrachloroethane based on the practical
quantitation limit, which equals a risk level of 6 x 10"5 for a lifetime residential scenario (at the time of
the 1996 ROD). To evaluate if the 1,1,2,2-tetrachloroethane groundwater cleanup goal remains valid,
this FYR conducted a screening-level risk evaluation. The screening-level risk review for groundwater
compared the groundwater cleanup goal from the 1996 ROD to the EPA's 2022 resident tap water
RSLs, which are based on the EPA's current toxicity values. Table L-l shows that the groundwater
cleanup goal for 1,1,2,2-tetrachloroethane is equivalent to risks just above the EPA's upper bound of the
cancer risk management range (1 x 10"4) and results in an HQ below the EPA's threshold of 1.0. 1,1,2,2-
Tetrachloroethane has only been detected once at the Site, in July 1993 at 2 |ig/L at MW-17. Table L-l
shows that this detection of 1,1,2,2-tetrachloroethane is equivalent to risks within the EPA's cancer risk
management range and results in an HQ below the EPA's threshold of 1.0.
Stack Emission Rates
The 1996 ROD established air performance standards to place limitations on the discharge of TCE and
vinyl chloride from the treatment system based on risk-based levels. To evaluate if the performance
standards for TCE and vinyl chloride remain valid, this FYR conducted a screening-level risk
evaluation. The screening-level risk evaluation for stack emissions rates was conducted by comparison
of the IUR factors from the 1996 ROD to the EPA's 2022 IlJRs, which are based on the EPA's current
toxicity values. Table L-2 shows that the EPA's 2022 IlJRs are more stringent for TCE and less
stringent for vinyl chloride than those IlJRs used to calculate emissions rates in the 1996 ROD.
Vapor Intrusion - Onsite
The results of the sub-slab soil gas and indoor air samples collected on site during the 2021 vapor
intrusion pathway assessment show that there is no current unacceptable risk, and no further
investigation/monitoring is needed at this time. The EPA agrees with these results and conclusions,
with the caveat that, should site conditions change, then vapor intrusion investigations/monitoring
should be conducted.
Vapor Intrusion - Off Site
Due to the presence of VOCs, this FYR Report evaluated the vapor intrusion exposure pathway for
wells with COC exceedances of cleanup goals within 100 feet of enclosed buildings (CMW-7 and
CMW-85, see Figure 3). This FYR conducted a screening-level vapor intrusion exposure pathway using
the EPA's Vapor Intrusion Screening Level (V1SL) calculator for residential exposure, which
incorporated the most current toxicity information and default exposure assumptions. The maximum
groundwater concentration in the deep zone of the bedrock aquifer (shallow alluvial aquifer and
intermediate zone of the bedrock aquifer data is not available in these sampling locations) during this
FYR period were used in the VISL calculator.
Vinyl chloride has been consistently detected at CMW-7 since 1999, ranging in concentrations from
5.2 |ig/L to 65 |ig/L. During this five-year review period, concentrations ranged from 6 |ig/L to 36 |ig/L.
Except for the June 2019 sampling event, VOCs had not been detected above MCL levels in CMW-85
since December 1997. Since 2019, concentrations of TCE in CMW-85 have been undetected, which is
consistent with historical results. The concentration of TCE in CMW-85 in June 2019 appears to be an
outlier. Table L-3 shows that the estimated vapor intrusion risk for residential exposures slightly exceeds
the EPA's acceptable risk range in well CMW-7 (2 x 10"4) and is above the target noncancer HQ of 1.0
L-l
-------
in well CMW-85 (2.0). This evaluation is a conservative assessment as there is shallow groundwater
overlaying the deep groundwater though, shallow groundwater is thought to not be impacted southwest
of the Site (where these two wells are located) due to the direction of groundwater flow.
Table L-l: Groundwater Screening-Level Risk Review
coc
1996 ROD
Cleanup Goal
(M«/L)"
Residential
RSLh
Screenine-Lcvel Ev aluation0
Risk Based
(1 x I0"6)
Noncancer
(HQ = 1)
Risk
HQ
1.1.2.2-
Tetrachloroethane
10
0.076
360
1 x 10-!
0.03
COC
July 1993
Detection
(filVL)"
Residential
RSLb
Screen in "-Level Evaluation0
Risk Based
(1 x 10*)
Noncancer
(HQ = 1)
Risk
HQ
1.1.2.2-
Tetrachlorocthanc
2
0.076
360
3 x 10"5
0.006
Notes:
a. The source is Table 9.1 of the 1996 ROD (PDF page 57).
b. Values arc the EPA's 2022 resident tap water RSLs for carcinogenic and noncancer effects:
htlDs://seiiiSDiib.eDa.gov/src/dociiiiient/HO/403648 (accessed 12/16/2022).
c. Screening-level risk evaluation: risk = (cleanup criterion (or detection) / risk-based RSL) (1 x 10-6) and HQ = (cleanup
criterion (or detection) / noncancer RSL).
d. The source is a Microsoft Excel file received from the EPA RPM Craig VanTrces on 10/18/2022.
Bold value = equivalent to a risk above the EPA's upper bound of the cancer risk management range (1 x 10~4).
Table L-2: Stack Emission Rates Risk Review
Air
Contaminant"
Allowable Emission Rates'*
IUR
Change
lb/hr
bv
M5J/m3
1996
ROD
Current'1
TCE
0.451'
0.06''
19,600''
107,500''
2 x Hi""
4 x Hi""
More stringent
Vinvl chloride
0.009d
0.001d
837d
2,174d
8 x 10"6
9 x 10"6
Less stringent
Notes:
a. An IUR has not been derived for cis-1.2-DCE. Therefore, a health-based emission rate could not be derived.
Therefore, the allowable emission rate for cis-l,2-DCE could not be compared to current standards.
b. The source is Table 9.2 of the 1996 ROD (PDF page 58).
c. Emission rate derived from 1 x 10-4 risk level and 70-year inhalation unit risk factor of 1.7/1,000,000 (p,g/m3).
d. Emission rate derived from 1 x 10"4 risk level and 70-year inhalation unit risk factor of 8.4/1,000,000 (p,g/m3).
e. The source is the EPA's Integrated Risk Information Svstem: httDs://www.eDa.eov/iris (accessed 2/16/2023).
lb/hr = pounds per hour
g/sec = grams per second
ppbv = parts per billion by volume
Hg/m; = micrograms per cubic meter
IUR = inhalation unit risk
L-2
-------
Table L-3: Vapor Intrusion Assessment
Well
coc
Maximum
Concentration - (jig/L)
VISL Calculator (residential exposure;
groundwater temperature 25.0° C)a
Cancer Risk
Noncancer HQ
CMW-7
Vinvl chloride
36 (June 2022)
2 x 10 4
0.5
CMW-85
TCE
10.5 (June 2019)
9 x 10"6
2.0
Notes:
a. VISL calculator: htIds://era-visl.onil.eov/cei-bin/visl search (accessed 1/27/2023).
C = Celsius
Bold = value exceeds the EPA's acceptable risk range or is above the target noncancer HQ of 1.0.
L-3
------- |