Posted by: Lawyer Sanders | February 3, 2015

Lawyer Sanders says KWDM holding an important public meeting on Federal Mogul site in Scottsvile, Kentucky.

The Kentucky Division of Waste Management (DWM) will meet with the public to discuss the status of the on-going environmental investigation at the former Federal Mogul facility located at 2640 Old Gallatin Road., Scottsville. The meeting is scheduled for Tuesday, Feb. 10, 2015, at 6 p.m. CST and will be held at the Allen County Courthouse located at 201 Main St., Scottsville.

Federal Mogul’s corporate predecessors started manufacturing operations at this location in the early 1960s, including metal cleaning, plating, and painting. The plant’s operations generated large quantities of chlorinated waste solvents, paint sludge, and other hazardous wastes. Spent chlorinated solvents and other chemical wastes were dumped in crude earthen pits and buried steel drums “over an extended period of time.”

Federal Mogul finally excavated and removed wastes disposed in the pits in June 2005 under the terms of a 1991 Agreed Order with the State. In June 2009, Federal Mogul installed an interim groundwater pump and treat system and the system started operating in July 2009, or more than 40 years after chlorinated waste solvents and sludge wastes were dumped into the unlined pits.

KDWM is currently coordinating on-going studies stemming from the historical release of chlorinated solvents that were in use beginning in the early 1960s by the former occupant, Scotscraft Inc., in the manufacturing of curtain rods. The company discontinued the process in 1981. As part of the investigation by DWM, it was found that during the 1970s plating waste and solvents had been disposed of in unlined earthen trenches located behind the facility.

Despite a RCRA Permit for the facility, the wastes sat in the ground for more than four decades. To absolutely no surprise, chlorinated solvents leached out of the degraded drums and migrated into the Karst geology. What was left of the waste materials in grossly degraded drums and around the trenches were removed from onsite trenches and properly disposed of offsite as a hazardous waste in 2005.

Nothing has yet been done to address the chlorinated solvent wastes that migrated offsite and the chlorinated wastes that are still in the karst geology.  Chlorinated solvents have physical and chemical properties that make this class of compounds particularly likely to cause groundwater contamination. The high densities and low viscosities of chlorinated solvents allow them to move readily downward as a DNAPL through the subsurface due to gravity.

The same properties that make chlorinated solvents potent ground-water contaminants make them difficult to locate or remove once they enter the ground-water system. Nowhere is this truer than in Karst settings. The former Federal Mogul plant is, of course, located in a Karst area of Kentucky. Spent chlorinated solvents generally enter the subsurface environment as DNAPL and migrate downward and laterally until local conditions favor their accumulation (Schwille, 1988; Cohen and Mercer, 1993; Pankow and Cherry, 1996). 

Current investigations involve the collection of surface water, groundwater, soil and air samples both on-site and offsite. Once the field investigations are complete, a remedial plan will be developed to address levels of contamination that pose a risk to human health or the environment.

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