Site Summary Profile
EPA ID: KYD006370167
Location: Calvert City, Marshall County, KY
Lat/Long: 37.050300, -088.323400
Congressional District: 01
NPL Status: Proposed: 12/30/82; Final: 09/08/83
Affected Media: Ground water, soil
Cleanup Status: Construction Complete – physical cleanup activities have been completed
Human Exposure Under Control: Yes
Groundwater Migration Under Control: Yes
Sitewide Ready for Anticipated Use: No
Site Reuse/Redevelopment: In continued use – industrial
Site Manager: Brad Jackson (firstname.lastname@example.org)
Current Site Status
The B.F. Goodrich contains several active and formerly active chemical plant areas. The site was placed on the National Priorities List (NPL) in 1983. The scope of the response under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) (a.k.a., Superfund) at that time consisted of a landfill and burn pits in the eastern most portion of the site area. Assessment and cleanup of the remainder of the site was being addressed by the Kentucky Department of Environmental Protection (KDEP) under the Resource Conservation and Recovery Act (RCRA). BF Goodrich Company, now known as United Technologies Corporation, (“BF Goodrich” or “Goodrich”) was the initial Potentially Responsible Party (PRP) conducting the assessment and cleanup work under Superfund and RCRA. The parties were later expanded to include PolyOne Corporation (PolyOne) and Westlake Vinyls, Inc., (Westlake) as the scope of work expanded under Superfund.
The eastern portion of the site shares a border with the Airco Superfund Site (the “Airco Site”). Because of their shared history and location, the BF Goodrich burn pits and landfill and the Airco Site PRPs consisting of Goodrich and the Linde Corporation, respectively, took Superfund-related cleanup actions at both sites. EPA approved the Records of Decision (RODs) (i.e., cleanup plans) in 1988 and the PRPs implemented the RODs in the 1990s. Some cleanup activities, such as ground water treatment and monitoring, are ongoing.
In 2007 and 2008, after a Five-Year Review of the BF Goodrich burn pit and landfill response in the eastern portion of the Site, EPA determined that the activities were not progressing as expected. In 2009, EPA and KDEP concluded that the most effective way to address the BF Goodrich Site was to combine the RCRA Site (previously overseen by KDEP) with the East Site and address them both under the EPA’s Superfund program. A large-scale site-wide investigation began in August 2010 to further assess the nature and extent of contamination, and potential risks at the BF Goodrich Site. EPA and KDEP will use this information to determine whether the PRPs, now consisting of Goodrich, PolyOne, and Westlake, will need to take additional short-term and long-term cleanup actions.
Site Location and Background
The BF Goodrich Site is located along Kentucky Highway 1523, approximately one mile northeast of Calvert City in western Kentucky. The Tennessee River borders the BF Goodrich Site to the north. A manufacturing facility owned by SKW Metals and Alloys, Inc. borders the BF Goodrich Site to the west and the Airco Site borders the BF Goodrich Site to the east. The BF Goodrich Site is the location of several chemical plants that have operated along the south side of the Tennessee River since the mid-1950s. Various parties have closed several areas at the BF Goodrich Site; other areas remain in active use. Chemical manufacturing businesses operating at the BF Goodrich Site include Westlake, Lubrizol Corporation, Cymetech, LLC, Carbide Industries, and Wacker Chemical Corporation. The majority of the BF Goodrich Site is fenced. A few residences are located in the area; the nearest is about a half-mile from the BF Goodrich Site. The larger area surrounding the BF Goodrich Site is a mix of industrial, rural, and agricultural uses.
Goodrich began chemical production operations at the BF Goodrich Site in 1953. One of the main chemicals produced over the years at the BF Goodrich Site is vinyl chloride monomer, which is used in the production of polyvinyl chloride (“PVC”). In 1990 and 1997, Westlake purchased most of the property and plant operations, and currently owns and operates a facility at the BF Goodrich Site. In 2000 and 2001, Cymetech LLC and Lubrizol Corporation (respectively), purchased property, and own and operate facilities at the BF Goodrich Site. PolyOne also owns and operates facilities at the BF Goodrich Site.
In 1983, EPA listed the BF Goodrich Site on the NPL. At the time of the listing, the scope of the Superfund cleanup focused on a former landfill and burn pit covering a two-acre area in the eastern portion of the Site. As part of the process, EPA and Goodrich also investigated whether contaminated ground water could possibly enter the Tennessee River. As noted previously, KDEP and EPA agreed in 2009 to expand scope of the Superfund response to include portions of the BF Goodrich site formerly managed under RCRA. With exception to the closed RCRA cell, assessment and cleanup of the 260-acre BF Goodrich Site is being fully managed under Superfund.
Investigations at the BF Goodrich Site found hazardous substances in the subsurface. Hazardous substances in the soil, groundwater, surface water and sediment include 1,2-dichloroethane (also known as "ethylene dichloride" or "EDC"), other chlorinated volatile organic compounds, benzene and mercury. Investigations at the BF Goodrich Site have also found non-aqueous phase liquid (NAPL) at various locations which is concentrated source material. Contamination at the BF Goodrich Site is impacting the Tennessee River at some locations.
Because of initial Superfund cleanup efforts at the East Site, it is not likely that contamination in the former landfill and burn pit area would threaten residents or workers. However, some contaminated ground water from the BF Goodrich Siteve periodically discharges into the Tennessee River. People could possibly come into contact with contaminants through direct contact or ingestion of the river water adjacent to the site. People living and working on or near the BF Goodrich Site are not using ground water for drinking water purposes.
In addition to the potential for exposure of contaminants to the public, contaminants may affect some of the organisms living in the river sediments adjacent to the site.
Investigation and Cleanup Responsibility / Oversight
The PRPs are leading the investigation and cleanup activities at the BF Goodrich Site, with oversight provided by EPA in cooperation with KDEP.
PolyOne, Goodrich, and Westlake formed a PRP group and started a large-scale, multi-phase investigation of the BF Goodrich Site in August 2010. The field investigation has been completed. It included the installation of over 250 soil borings, and the collection and analysis of over 3000 groundwater, surface water, soil, sediment, and air samples. The results were to be compiled into a Remedial Investigation Report (“RI Report”) due in June 2013. However, differing opinions regarding the interpretation and use of the data available at the BF Goodrich Site resulted in the submittal of separate reports by the PRPs. Two reports were jointly submitted by Goodrich and PolyOne and a report was submitted by Westlake. EPA was unable to have the parties consolidate the RI reports into one report. EPA took-over the writing of the RI Report and Risk Assessment. A draft RI Report is planned for July 2014.
A feasibility study of potential cleanup alternatives has been delayed pending the completion of the RI Report. A numerical groundwater model has been prepared to evaluate, among other things, the interaction between the groundwater and the Tennessee River. The model will be helpful in evaluating the effectiveness of various cleanup alternatives. The groundwater model and evaluation of alternatives will be summarized in a FS Report. The FS Report schedule will be determined once an RI Report is completed. In the interim, the PRP’s have been working on various elements of the FS report.
In 1988, EPA issued a ROD for the burn pit and landfill located in the eastern most portion of the Site. Goodrich initiated several cleanup activities required in the 1988 ROD, including:
- Constructing a flood protection dike.
- Improving the existing landfill cap.
- Installing a leachate removal system.
- Combining surface soil and drainage ditch sediment.
- Installing a dual phase extraction system.
- Constructing an impermeable cap over burn pit areas.
- Installing site fencing.
- Placing deed restrictions on the site property.
- Ground water monitoring.
Concurrently with the 1980’s and 1990’s Superfund work, KDEP led RCRA-related cleanup actions on most of the remainder of the site. Goodrich closed a series of disposal ponds, consolidated contaminated material into an on-site landfill (i.e., RCRA Closure Cell), and implemented a multi-well groundwater collection and treatment system.
In the late 1980s, KDEP required Goodrich to start extracting and treating contaminated ground water under the RCRA program. The goals of the “pump and treat program” are to stop contaminated ground water before it discharges into the Tennessee River and to extract and treat concentrated areas of contaminated ground water. KDEP also required Goodrich to obtain a RCRA Corrective Action Permit and conduct environmental studies to investigate the source of contamination and how far the contamination had spread on the RCRA Site.
Goodrich was responsible for both the CERCLA and RCRA related cleanup work. As mentioned above, Goodrich installed a ground water collection, treatment and disposal system for both areas. An eight-well ground water collection and treatment system was initially installed in the mid-1980’s, under the RCRA program. The system was expanded in 1992, as required by the Superfund ROD and RCRA Corrective Action Permit. A final expansion of the well system under the RCRA Corrective Action Permit increased the total number to 51.
The treatment system discharges the treated ground water to the Tennessee River. Today, the PRPs monitor changes in ground water quality and water levels through a 185-well ground water monitoring system.
Later in 2006, a second Five-Year Review of the burn pit and landfill in the eastern portion of the site found that cleanup actions to date were protective of people and the environment in the short-term. However, in the long term, there was a need for additional work to improve clean-up progress. The Five-Year Review found that ground water contamination was not decreasing to levels anticipated by EPA. As a result, EPA concluded that the nature of the contamination, such as contamination in NAPL form, may be impacting the clean-up activities at the eastern burn pit and landfill. In 2007 and 2008, EPA determined there are areas of NAPL at and near the burn pit and landfill that are impacting the clean-up progress. In addition, there is evidence of NAPL being present at the RCRA Site. EPA and KDEP concluded that the most effective way to address contamination at the BF Goodrich Site was to expand the scope of the Superfund response to include the entire BF Goodrich Site (with the exception of the RCRA closure cell).
EPA negotiated legal agreements with the BF Goodrich Site's PRPs to investigate and clean up the BF Goodrich Site. Initial agreements date from the 1980's and 1990's with the agreement to conduct an RI and the eastern burn pit and landfill cleanup. In 2008, Goodrich and PolyOne Corporation entered into a legal agreement with EPA to conduct a forcused remedial investigation and feasibility study for the eastern burn pit and landfill area. In December 2009, after EPA and KDEP decided to expand the scope of the Superfund response, the PRPs entered into a legal agreement with EPA to conduct an expanded remedial investigation and feasibility study that replaced the previous legal agreement.
EPA has worked with the community and KDEP to develop a long-term cleanup plan for the BF Goodrich Site, reflecting the EPA’s commitment to safe, healthy communities and environmental protection. Community engagement and public outreach are core components of EPA program activities.
EPA has conducted a range of community involvement activities to solicit community input and to ensure the public remains informed about BF Goodrich Site activities throughout the cleanup process. Outreach activities have included public notices, interviews and public meetings, as well as meeting with local leaders.
In 2010, EPA held an open house meeting to update the community on the BF Goodrich Site’s status and answer community questions. EPA also periodically briefs the Calvert City Council on progress at the BF Goodrich Site.
A draft RI Report is to be submitted to EPA in July 2014, and an FS Report will follow. The information from these reports as well as the groundwater modeling report will be used to evaluate possible contamination effects and related cleanup options.
EPA keeps additional BF Goodrich Site related documents and information in a Site Information Repository at the location below. EPA also posts documents about BF Goodrich Site, when available, on EPA’s CERCLIS Site Profile page. For documents not available on the website, please contact the Region 4 Freedom of Information Office.
Marshall County Public Library
23 Park Road
Calvert City, KY 42029