1. Federal Mogul Department for Environmental Protection Kentucky Division of Waste Management February 10, 2015 Presented by Chris Jung To Protect and Enhance Kentucky’s Environment

2. Division of Waste Management Site Location

3. Division of Waste Management Federal Mogul

4. Division of Waste Management Federal Mogul

5. Division of Waste Management

7. History of the Facility

8. Division of Waste Management HISTORY OF FACILITY In 1961, Scotscraft, a division of Kirsch, manufactured drapery and curtain rods (zinc plating line). Sometime after 1971, Scotscraft expanded operations to the former Wood Master building across the street that is currently occupied by Sumitomo. In 1981, Cooper Industries purchased Kirsch. In 1990, Cooper ceased all production at the Scottsville facility. In mid 1990s, Cooper Industries re-opened the Scottsville facility and began reconditioning and manufacturing brake pads as Wagner. In 1998, Federal Mogul acquired Cooper Industries and continued the brake pad manufacturing operation. In 2006, Federal Mogul closed the Scottsville facility. In 2013, Industrial Warehousing Inc. moved into the building and uses it as a warehouse.

9. Division of Waste Management PRIMARY WASTES GENERATED AT THE FACILITY  Metals:  Zinc  Cyanide  Both were common ingredients in the plating process for the manufacture of the curtain rods.  Volatile Organic Compounds (VOCs):  Trichloroethylene (TCE)  Dichloromethane  Both are common ingredients in many degreasers.

10. Division of Waste Management Environmental Regulation Cooper disposed of wastes in trenches until 1979. In mid 1970’s through 1980’s laws were passed that controlled how wastes were disposed. Inspections of the facility by the KY Division of Waste Management in the 1980s identified improper storage of hazardous wastes. A Notice of Violation was issued to the facility in 1982 for improper storage of drums of hazardous waste.

11. Division of Waste Management Drum Storage

12. Division of Waste Management Drum Storage and Site Investigation In 1991, Cooper entered into an Agreed Order with the Division that required the closure of the drum storage areas. The Agreed Order required Cooper to investigate whether there were releases at any other areas at the facility were solid or hazardous wastes were handled.

13. Division of Waste Management Facility Assessment In July 1991, a RCRA Facility Assessment (RFA) was completed that identified areas behind the facility that required additional investigation for possible releases. In 1993, the investigation of the area behind the facility was initiated. The investigation looked at contamination in four different areas: –Soil –Groundwater and Surface water –Air

14. Division of Waste Management Soil Investigation Multiple samplings events and investigations were conducted at the east side of the facility. The investigations included over 35 soil borings.  Cyanide 370 ppm (Res. Limit = 1600 ppm)  Arsenic 37 ppm(Res. Limit =.39 ppm)  Trichloroethylene 2,779 ppm(Res. Limit = 2.8 ppm)  Cis-1,2-Dichloroethylene 955.9 ppm (Res. Limit = 780ppm)

15. Division of Waste Management Boring Locations

16. Division of Waste Management Pit Excavation Based on our data from the soil borings and employee interviews, the disposal pits were excavated down to bedrock. Approximately 52 drums and 172 cubic yards of soils were removed and disposed of at an approved offsite location.

17. Division of Waste Management Pit Location

18. Division of Waste Management Excavation

19. Division of Waste Management Excavation

20. Division of Waste Management Temporary Storage

21. Division of Waste Management Groundwater and Surface Water Investigation

22. Division of Waste Management Groundwater Investigation Between 1998 and 2010, a total of 18 monitoring wells were installed at the site. The highest recorded concentration was found in the MW-14B. Groundwater sample tested in 2005 at MW-14B had a TCE concentration of 334 ppm (MCL.005 ppm).

23. Division of Waste Management Investigation

24. Division of Waste Management Interim Measures Based on the elevated sample results, Federal Mogul submitted a plan to install extraction wells at the facility. In 2005, work began on converting monitoring wells MW-12B and MW-14B into extraction wells. Approximately 5000 gallons of water are pumped per day. The extracted water is treated onsite by an air stripper to remove contaminants.

25. Division of Waste Management Investigation

26. Division of Waste Management Surface Water Investigation  In 2005, sample results from Ramble Creek had elevated concentrations of trichloroethylene (TCE) and cis-1,2- dichloroethylene (DCE).  Highest recorded TCE concentration was 144 ppb (MCL 5 ppb) in 2006.  Last four monitoring events in 2014 of Ramble creek found the following results for TCE concentration: 22 ppb 6.1 ppb 6.8 ppb 7.2 ppb

27. Division of Waste Management Dye Trace A dye trace study was performed in 2006 to find any additional surface water that might be affected by the contamination at this site. Dye was injected into monitoring wells and one of the previously excavated pits located to the east of the Federal Mogul property.

28. Division of Waste Management Dye Trace Study Area

29. Division of Waste Management Confirmatory Sampling Ramble Creek

30. Division of Waste Management

31. Air Investigation

32. Division of Waste Management Air Monitoring In 2012, the Division requested offsite sub soil air monitoring to the west of the facility. Three outside locations were selected, and a 24-hour test was conducted. One sample result evidenced elevated concentrations of trichloroethylene (620 ppb).

33. Division of Waste Management Indoor Air Sampling

34. Division of Waste Management Trichloroethylene (TCE) EPA Region 9 Interim TCE Indoor Air Response Levels:  Residential 2 µg/m³  Commercial/Industrial 8 µg/m³ (8-hour workday)  Commercial/Industrial7 µg/m³ (10-hour workday)

35. Division of Waste Management Indoor Air Sampling In 2012, the Division requested that Federal Mogul take additional air samples including indoor the houses west of the facility.

36. Division of Waste Management Indoor Air Results

37. Division of Waste Management Outdoor Air Sampling

38. Division of Waste Management Outdoor Air Sampling

39. Division of Waste Management Next Phase of Investigation

40. Division of Waste Management Projected Work Federal Mogul will continue to perform air and groundwater monitoring. Federal Mogul is currently implementing a remediation pilot injection project in the former burial pits in the rear of the facility. Federal Mogul has recently submitted a plan to install additional on and offsite groundwater monitoring wells.

41. Division of Waste Management Geophysical Investigation Several geophysical studies have been performed both on and offsite, to identify locations for sampling.

42. Division of Waste Management Proposed Monitoring Wells

43. Allen County Public Library 106 West Public Square Scottsville, KY 42164 Division of Waste Management 200 Fair Oaks Frankfort, KY 40601 Point of contact: Tina Fisher (502)564-6716 (fax) (502)564-9232 Email: tina.fisher@ky.gov File Copies